Fair Lending Plan
Complying with anti-discrimination rules may represent one of the largest efforts of lender’s compliance managers. The CFPB, OCC and FDIC all have announced plans to increase supervision. This plan establishes a company’s policy basis for Fair Lending compliance, but also addresses support mechanisms such as 2nd level review, application definition, training for personnel, loan level audit and operational review. It is important to note that some elements of Fair Lending documentation are difficult to address strictly in the compliance plan. For instance, you will need to ensure that elements within this plan get reflected in your origination and processing procedures, but particularly in your credit policy and procedures such as those for second level review and origination and marketing policies, are in the compliance plan, but must be integrated with operations. Elements of your own policies, such as these, may be requested in a Fair Lending Examination but are beyond the scope of the Fair Lending Plan.
TIL-RESPA Integrated Disclosure Policy and Procedure (TRID)
Effective 10/3/2015, the combined disclosure rule requires the consolidation of Truth-in-Lending and Real Estate Settlement Procedures Act requirements for content and timing. This primarily means that the most rigorous elements of both rules now apply to one process. Timing and content must be set forth in any standard process, but more critically, the rule sets forth specific deadlines for curing errors. This makes the audit process critical for ensuring compliance.
USAVA Lending is a division of First National Funding, LLC
MB 0921703 NMLS ID 966439