closely scrutinized by the agencies, including the fairness of scoring models. Expect more commentary from the regulators on how various credit
scoring models behave and whether there are inconsistencies that should
be addressed by individual banks.
■ ■ ■ Non-English speaking consumers. Also called Low English Proficiency
(or LEP) consumers, how you deal with these consumers should be a focus
of your program going forward.
Keep in mind also that several state Attorneys General have very publicly
announced that they will take an active role in fair lending enforcement as well.
Mortgage servicing. Fair lending isn’t the only important issues to consider
when it comes to mortgage servicing. Now that we’re about four years into
the new rules under RESPA for servicing consumer mortgages, technical
compliance with the rules is expected. We’ve also had some additions to
those rules in the past few years, so be sure your processes are operating
as you expect. A few problem areas that should have your full attention (as
they’ve been the focus of various enforcement actions) include notices and
communications to delinquent borrowers, the loss mitigation application
process (which is incredibly detailed, with many timing and notice requirements), and any waivers.
BSA/AML. Similar to HMDA, 2018 should not have been viewed as the
finish line for the new Beneficial Ownership rule, but the beginning. Compli-
ance with this rule is complicated and time-consuming; you need to be (more
than) ready for your first BSA exam—including the new rule. As stated above,
further guidance and interpretation of the rule may be forthcoming, so make
sure you’re ready to adjust on the fly. Also similar to fair lending, enforcement
of BSA rules (really any sort of financial crimes law or regulation) has not
decreased at all. To the contrary, we’re continuing to see a steady stream of
BSA problems in banks large and small. Make sure you’re not one of them.
To be sure, this is not a comprehensive list of priorities for this year, but it’s
a good place to start. We can also be certain that issues will arise that no one
sees coming. This year promises to be a busy year in the world of compliance.
While we may not see a new rule to the scale of TRID or 2018 HMDA this
year, there is still plenty to pay attention to, in order to keep your program
in the place it should be. ■
ABOUT THE AUTHOR
CARL G. PRY, CRCM, CRP is managing director for Treliant LLC., in Washington,
D.C., where he advises clients on a wide variety of compliance, fair lending,
corporate treasury, and risk management issues. Over the last two decades,
Carl has held senior leadership positions including senior vice president and
compliance man-ager for the Compliance and Control Department at Key Bank
in Cleveland, Ohio; vice president of regulatory services at Kirchman Corp. in
Orlando, Florida; and manager in the Finance and Performance Management
Service Line at Accenture in Chicago, Illinois. He also serves on the ABA Bank
Compliance Editorial Advisory Board. Reach him via email at firstname.lastname@example.org
or by telephone at (440) 320-4662.
Risk Solutions that Work for You.
• Universal Risk Management
• Integrate All Risk Silos
• Three Lines of Defense
• 90 Day Implementation
• Vendor Relationship
• Vendor Risk Assessments
• News Monitoring Risk Alerts
• Due Diligence Management
Learn why Procipient® and VendorInsight® customers give us a 4. 6 out of 5-star rating!
REQUEST A FREE DEMO TODAY