TOPIC: Quality Control

Compliance Monitoring/Testing Plan for a Loan Product Serviced by a Third-Party

Employee at a bank ($13.6BUSA)
Hello CBANC Family,

I am once again reaching out for help. I am hoping I can get help from you all. We will be launching an unsecured personal loan/consumer loan product in the near future, and while the loans will remain in our books,  a third party will handle the origination and servicing of these loans. Do any of you have any compliance testing/monitoring plan(s) that you are willing to share with me, please? Any guidance will be immensely appreciated. Many thanks.

    Contacting your customers/members

    Employee at a credit_union ($291MUSA)
    We are looking at different avenues for contacting members/customers regarding transactional info on their account; not marketing.  We have some that are not responding to mailed letters or phone calls regarding their dormant accounts and we are considering emails.  We have read the CAN-SPAM reg and will not be marketing to them and will still include the option to "opt out".  We have staff that want to use facebook messenger, but I don't feel social media messaging is the way to go.  Do you use any social media messaging to contact your members?  Do you have a sample of your authorization that your customer/members sign?  We will be running this by legal, but wanted to see what others are doing as we update our policies and procedures. 

      IRS 4506T snafu

      Employee at a bank ($677MUSA)
      For lenders selling to FNMA, tax transcripts are part of their required QC so we routinely provide a 4506T, which is only good for 120 days, for signature with the early disclosures. We would order the transcript but go ahead with the closing anticipating receipt of the transcript to have for QC.

      However, our vendor recently sent us the following:
      Order Cancelled—This order had been sent to the IRS during the shutdown for COVID-19 and we have been waiting for processing. However, it has become apparent that the IRS “missed” or “deleted” thousands of orders that were waiting in their queue. Due to the unpredictable way that they are processing orders, there is no way to determine status on this order. We are cancelling the order WITHOUT CHARGE to you. THEREFORE, if you still need transcripts for this/these borrowers, you MUST place a NEW order(s). We sincerely apologize for the inconvenience, but this is beyond our control.

      Curious how others are handling this. Are you going back to the borrowers for an updated form? Has anyone heard that FNMA has made an exception for transcripts ordered during the shutdown period?
      I don't want to sweep this under the rug if it's going to come back on me later.