We received a couple of follow-up questions to Matt’s excellent presentation. Matt’s answers follow each question:
Question from (private): What are some examples of the types of complex reviews you are seeing banks consider outsourcing?
Answer from Matt Evans – BSC to Private: In addition to conducting compliance audits of the typical consumer compliance regulations, we have conducted specific audits for Fair Lending, HMDA Scrubs, and more recently “Dodd-Frank” reviews of the new provisions. I’m calling this a “Dodd-Frank Check Up.”
Question from FNB Bank to Everyone: Based on what you’ve seen initially, what do you anticipate to be the most common errors from the new rules?
Answer from Matt Evans – BSC to Everyone: Thanks for the question FNB!! Although everything is new, we are seeing a disproportionate number of questions in the ATR area. This probably is NOT a surprise to you! We are seeing many bankers very frustrated and confused by the ATR rules. The on-going question is this: we have long-term borrowers who have always paid as agreed. Now they will not qualify under the ATR rules. What do we do?????? We acknowledge that each situation is completely a case-by-case, so you have to assess everything individually, and based on its own merits. We anticipate this continuing to be a sticking point.