Recent Compliance Issues: 3/4/16 – 3/17/16

1. In today’s world of instant messaging, it is important to understand what social media use and compliance can look like for the mortgage and lending industry. Although the FFIEC released their guidance for social media use two years ago, there’s limited information to help lenders bridge the gap between consumer demand and industry compliance. We are witnessing the potential far-reaching uses of social media. For that reason, banks need to be aware of the risks of social media use in the residential mortgage industry. It is critical to know how to avoid those risks, such as privacy breaches, recordkeeping failures, and deceptive advertising practices.
Allow our experienced, former, Federal regulators to review your social media activity, including policies, procedures, and oversight to ensure that your institution is not in danger of violating mortgage and other consumer compliance rules and regulations.

2. Feedback from bankers has helped the Consumer Financial Protection Bureau improve supervision and the agency’s complaint database. At the same time, banks should be monitoring the tracking, review, and analysis of their own consumer complaint database. The effectiveness of an institution’s complaint review process is a critical element in the regulators’ assessment of your overall “Compliance Management System” (CMS).
Our former, Federal, compliance examiners can review your institution’s CMS to determine if your bank is on the correct path in reducing exceptions with respect to consumer compliance.