TOPIC: Procedures

Procedures for Handling Non-Public Information

SVP at a bank ($266MUSA)
I am looking for some information in order to respond to a request from Fannie Mae. I am looking for a sample procedure that covers how Non-Public Personal Information in excess of what is required by the Bank is handled. This would be part of a NPI Collection and Use Procedure. We really don't collect excess personal information but Fannie Mae still is asking for a procedure. Can someone share their procedures? Thank you.

    Vehicle title lien expiration

    VP at a credit_union ($51MUSA)
    In Pennsylvania vehicle title liens are only effective for 6 years, other types have differing times - 8 years for truck tractors or trailers weighing in excess of 10,000 pounds, 20 years for motor homes or recreational vehicles (types RECT or MTRH), 30 years for a mobile home or emergency vehicle, and 10 years for boats.  We may extend the lien for additional time periods by filing and paying a fee during the 6 months preceding expiration.  This is not something we regularly did because usually the vehicle, etc. pays off prior to expiration or there is a relatively small balance on the loan and it pays off within a year of expiration.  In general people do not know that liens expire and as long as we gave them back their paper title with evidence of satisfaction of the lien all was well.

    It recently came to our attention that under ELT after the lien automatically drops off, there is a 90 day grace period for the member to receive a paper title without having to pay the full duplicate title fee - in PA this is $81.00. The credit union releasing the lien on ELT will not produce a paper title, and we are not able to request one since we are no longer listed by the state as a lienholder.  

    To add insult to injury, our ELT vendor is not able to produce an expiration report for us based on the type of collateral and the respective expiration dates. We can fish them out using a Lien Date Status report, but have to review closely to weed out ones needing updated within the next 6 months.  My first instinct is to just order a paper title on all that will be expiring in the next 6 months, but then if we do decide to extend our lien it increases the cost to $81.00 from $26.00 for motor vehicles alone. 

    Has anyone else addressed this issue?  If so, would you mind sharing your policy and procedure for handling it?  Thankfully we have few instances of collateral that is titled in other states, but I don't even want to think about how we go about monitoring possible expirations on those. I thank you for you for your input.

      FCRA & Human Resources - Procedures for Denying Applicants Due to Credit/Background

      AVP at a bank ($3.4BUSA)
      Good morning, 
      Looking for any policies and procedures, training, or other resources that your institution uses that complies with the notification requirements under FCRA for taking adverse action on applicants for employment due to information in whole or in part of their credit report. Thanks in advance!

        Free Webinar | How to Develop and Defend Your Risk-Based AML Program | 1 CAMS Credit

        Tuesday, October 29 | 2 p.m. EST/ 1 p.m. CST
        Presented by Terri Luttrell, CAMS-Audit
        Register here

        The OCC, FDIC, Federal Reserve, NCUA and FinCEN released a statement emphasizing their “risk-focused” approach to examining Bank Secrecy Act / anti-money laundering compliance programs. Is your AML program current with examination requirements and expectations? Join us for a free webinar where Terri Luttrell, CAMS-Audit, will give you an inside look into a risk-based program, how to develop a risk based program, and what examiners will be looking for.

        Join to learn:
        • What examiners announced in their statement this summer
        • What is required in a comprehensive enterprise wide risk assessment
        • How your AML program should center around unique risk profiles
        • Pitfalls to avoid that might otherwise flag examiner concerns
        • What to expect during your next examination in regards to your risk-based approach
        Save your seat!

          Free Webinar | Best Practices for Credit Analysts at Banks

          Monday, October 21
          2 p.m. EST/ 1 p.m. CST
          Register 

          Current economic conditions seem to suggest that the next U.S economic downturn is on the horizon. With that in mind, it is becoming increasingly important to have the right credit policies and procedures in place to ensure your institution understands its customers and members throughout the lending process.

          Join this webinar session to learn common best practices for credit analysts when dealing with current and future market conditions.

          Join to Learn:  
          • Best practices for loan and financial statement analysis  
          • How to identify problem loans and the benefits of early detection 
          • Way to optimize deal flow 
          Presenter: Ancin Cooley, Principal, Synergy Bank Consulting

          Save your seat! 

            Loan Material Change Form

            VP at a bank ($129MUSA)
            Would anyone have a sample of a Material Change Form that is filled out by the loan officer to request a modification?  And if written procedures would accompany that sample, I would not be upset..  :)  
            Thanks for your time. 

              Free Webinar | Considerations for Automating AML Monitoring | Earn 1 CAMS Credit

              Friday, September 20, 2019
              2:00 PM ET / 1:00 PM CT
              Presented by Kevin Gulledge, CAMS
              Register today! 

              Financial institutions have many choices when it comes to AML solutions. These solutions can be very complex in nature, or they can sometimes be very basic. Join us for this free webinar where we will discuss the top issues that bank and credit union management faces when selecting, implementing, and using an automated AML monitoring software solution. We will look at the challenges faced by the financial institutions including discussions about policies and procedures, customer and transactional data, budget constraints, core systems, teller systems and more.
              Join to learn:
              • Understand the different types of automation that can support your financial institution’s BSA/AML program
              • Identify common points of failure that institutions may have in implementing a solution along with recommended solutions
              • Explain the implications that your BSA Program and Policies and Procedures may have on vendor or software selection
              Save your seat! 

                MSB Security Deposit

                SVP at a bank ($3.3BUSA)
                Would like to get a poll as to what other banks may require to be on deposit when banking an MSB to cover possible chargebacks after or when a MSB relationship ends. We currently have several MSBs that we do not require any sort of deposit and are concerned that should we or the MSB close the relationship, how do we ensure we get covered for any possible chargebacks that may come after the accounts are all closed?

                Comments/thoughts???

                  Free Webinar: CU Best Practices for Credit Analysts

                  Register today!

                  Current economic conditions seem to suggest that the next U.S economic downturn is on the horizon. With that in mind, it is becoming increasingly important to have the right credit policies and procedures in place to ensure your credit union understands its members throughout the lending process.

                  Join this webinar session to learn common best practices for credit analysts when dealing with current and future market conditions.

                  Join to Learn:  
                  • Best practices for loan and financial statement analysis 
                  • How to identify problem loans and the benefits of early detection 
                  • Way to optimize deal flow 
                  Tuesday, September 10, 2019
                  2:00 PM ET / 1:00 PM CT
                  Presenter:
                  Ancin Cooley, Principal with Synergy Credit Union Consulting, Inc.

                  Save your seat!