2024 Lending Compliance Triage Conference
AGENDA
REMOTE FEED ACCESS TIMES
 10:00am - 6:00pm Eastern Time
  9:00am - 5:00pm Central Time
     8:00am - 4:00pm Mountain Time
   7:00am - 3:00pm Pacific Time

Conference begins each day at the specified time which is dependent on which time-zone you reside in.
   
Day 1
CENTRAL TIME
SESSION
9:00 - 9:55 Intro and Fair Lending Risk Assessments & Mitigation - John Burnett, Kimberly Boatwright
9:55 - 10:05 BREAK
10:05 - 10:50Open Banking - What the 1033 Rule has in store for Banks- Maureen E. Carollo
10:50 - 11:00 BREAK
11:00 - 12:00 Case Study: Escrow Analysis - Learn by Doing - Rebekah Leonard
12:00 - 1:00 LUNCH
1:00 - 1:50 FCRA: Hard Pulls, Soft Pulls, and What to Do About Trigger Leads - Rebekah Leonard
1:50 - 2:00 BREAK
2:00 - 2:50 Appraisal Bias / ROV: The Latest Regulatory Guidance - Maureen E. Carollo
2:50 - 3:00 BREAK
3:00 - 3:50 CRA Update: Where are We Now? - Kimberly Boatwright
3:50 - 4:00 BREAK
4:00 - 5:00 Panel Discussion - Q and A
Adjourn - See you tomorrow!
  
Day 2
CENTRAL TIME
SESSION
9:00 - 9:50Case Study: Using the FFIEC APR Calculator on a TRID Loan - Rebekah Leonard
9:50 - 10:00 BREAK
10:00 - 10:50 Flood Update: Helping You Keep Your Head Above Water - Kimberly Boatwright
10:50 - 11:00 BREAK
11:00 - 12:00 UDAAP; Unfair Loan Fees; & the CFPB's Unfair Discrimination view - Maureen E. Carollo
12:00 - 1:00 LUNCH
1:00 - 1:50 Loan Servicing and Recent Enforcement Actions - Maureen E. Carollo
1:50 - 2:00 BREAK
2:00 - 3:00 1071 Update: Time to Get Serious - Kimberly Boatwright
3:00 - 3:10 BREAK
  3:10 - 3:55 AI and Compliance: The New Frontier - Rebekah Leonard
3:55 - 4:05 BREAK
4:05 - 5:00 Panel Discussion - Q and A
Adjourn - Thank you for attending!

Fair Lending Risk: Assessments & Mitigation - Kimberly Boatwright
With increased regulatory scrutiny and issues with equitable access to credit in the news weekly, it is more important than ever to prioritize fair lending compliance. This session will focus on current fair lending issues and enforcement actions. You'll come away with good insight to proactively maintain compliance and identify areas for improvement within your institution's lending process.
  • Withstand regulatory scrutiny.
  • Improve risk management processes.
  • Enhance customer relationships.
  • Strengthen your brand and reputation within your community.

Section 1033 - Open Banking - Maureen E. Carollo
This CFPB rule is still in proposed form, the ANPR having been issued back in October of 2020 and we are still waiting for the final rule. This is another one that the Dodd-Frank Act requires to become finalized as well. However, all bankers need to become familiar with the concept of what these requirements are. In a nutshell, this is the "break up with my bank" rule, but do we really understand what this means in relation to our regulatory record retention obligations, the consumer's privacy, their information portability, information security, etc.? We will dive deep into these issues and more for a much better grasp of the sections that can be tackled more easily with systems in place and address the ones that the regulators are still contemplating that still need work before the rule is finalized.

CRA Update: Where are We Now? - Kimberly Boatwright
Compliance with the Flood Insurance regulations should be easy. Yet it continues to be one of the most commonly cited issues in violations and penalties. Join us to untangle the complexities of Flood Insurance and maintain a compliant program. This session examines the Flood Insurance regulations, and Interagency Questions and Answers, with a special focus on common issues and recommendations for achieving compliance.

Flood violations continue to cost institutions thousands of dollars of dollars every year! This session examines the requirements of the Interagency Final Rules including:
  • The exemption from coverage for any structure that is part of a residential property but is detached from the primary residential structure and does not serve as a residence.
  • The revised Flood Hazard notice.
  • The requirement to offer the option to escrow flood insurance premiums and fees on loans outstanding as of January 1, 2016.
  • The revisions to the rules for force-placing flood insurance; and
  • The requirements that lenders accept private flood insurance.

Case Study: Escrow Analysis - Learn by Doing - Rebekah Leonard
Escrow compliance is tough and intimidating! Several regulations require it be done right, including RESPA, TILA, TRID, HPMLs, Flood, and Fair Lending. Moreover, the business of escrowing for taxes and insurance is a high-stakes endeavor - with errors bringing consumer harm and potential reputational damage. Failing to accurately pay taxes when due will cause fines and penalties, and could make your bank look inept in its fiduciary capacity. Failing to accurately disclose escrow items or properly analyze escrow accounts will bring regulatory violations and upset borrowers. There is a lot on the line!

This session will provide a high-level overview of regulatory escrow rules, then delve into a case study to demonstrate how escrow analysis is done - right down to the aggregate analysis! Move beyond the academic discussion and into the practical... and come away with a far better understanding of your disclosures and notices, to the benefit of both your borrowers and your compliance management program!

FCRA: Hard Pulls, Soft Pulls, and What to Do About Trigger Leads - Rebekah Leonard
The FCRA is a complex law that mandates how users and furnishers of consumer reports must behave. A huge cornerstone of the law is "permissible purpose": if you have it, you are golden and can use a credit report for many things; without it you are breaking the law. Another cornerstone is "accurate" credit reporting. If a consumer is seeking credit, other users have a right to know it... after all, that consumer is actively in the market to indebt themselves.

So where does this leave "soft pull" credit checks, which access credit report data without leaving an inquiry fingerprint? Are they being done with permissible purpose, and are they accurately reflecting credit shopping? Well, that's complicated. Credit agencies are rolling out new credit report products to provide creditors with soft pull reports (with full report data!) but without showing the inquiry on the history, at least not right away. They are offering these products to help consumers avoid "trigger leads", which are immediate and outrageously intrusive prescreening offers made by other creditors and triggered by inquiries. To be clear, trigger leads are only possible because credit agencies are selling prescreening products too. Yes, credit agencies are offering solutions to problems of their own making and collecting fees on both ends. Congress has taken note and might amend the FCRA to close the trigger lead loophole. Until they do, learn what you need to know to stay on the right side of compliance in this complicated and challenging area.

Appraisal Bias 2.0 - Maureen E. Carollo
"Appraisals have been hot in the news for the last couple of years because of the continual spotlight of discriminatory practices of residential appraisals. The regulators have continually focused on the redlining aspects of bank's handling of lower valuations that have been returned by appraisers and the responses of the banks (or lack of) to their customers who have concerns about these lower values. The prudential agencies have provided proposed guidance and then the GSEs also released expected procedures and guidelines they expect the mortgage industry to implement and have as part of their standard operating procedures.

Some of the other concerns are with the model versions that are being used to provide valuations in the mortgage industry that we are all familiar with-AVMs or automated valuation models. Models in general have drawn much interest as have all machine learning and artificial intelligence since regulators need to understand what and how the box is calculating the value or all systems that range from credit scores to home values. The concern is to ensure that human bias has not been allowed to creep in and allowed to alter the property values.

Also, the agencies have just released the long-awaited final guidance on the Reconsideration of Value (ROV) and the final guidance on AVMs so we will cover these as well."

CRA Update: Where are we Now? - Kimberly Boatwright
NEW CRA Rule released Oct. 24, 2024. We have your first look. What will the new rules mean to your bank and how might you need to adjust to comply? The Community Reinvestment Act impacts banks in many ways and is one of the few ratings your bank will receive which is intended to be public knowledge. There is reputational risk involved as well as its effects on a bank's ability to expand and grow. There are a lot of questions surrounding CRA right now.
  • What are the major revisions now that the 1,466 page rule is out?
  • What's all the hoopla about REMAs, are they officially in the CRA or not, and what should you be doing about them?
  • Is it true that violations not typically CRA-related are influencing CRA ratings? What are some examples and what can your bank do about it?
  • What are the advantages and disadvantages to the different ratings, especially Needs to Improve vs. Outstanding?
  • What are some of the common questions and misperceptions about CRA that we are hearing and that you may learn from?

Case Study: Using the FFIEC APR Calculator on a TRID Loan - Rebekah Leonard
Mistakes happen. Even strong compliance programs can have a slip-up, and you may find your bank has wrongfully disclosed the APR or Finance Charge on a loan. So what? What does it really matter if the number is wrong? Plenty! The Truth in Lending Act mandates accuracy in disclosures, and there are consequences when that doesn't happen. These consequences are significant, and do not go away by "just redisclosing" the correct figure.

Learn how to identify errors that require restitution to the borrower, and how to find out exactly how much restitution is needed. We'll go through a case study with a TRID loan (because those bad boys bring even more zest to the party) to teach you the practical tools and calculations to make things right when things go wrong.

Flood Update: Helping You Keep Your Head Above Water - Kimberly Boatwright
Compliance with the Flood Insurance regulations should be easy. Yet it continues to be one of the most commonly cited issues in violations and penalties. Join us to untangle the complexities of Flood Insurance and maintain a compliant program. This session examines the Flood Insurance regulations, and Interagency Questions and Answers, with a special focus on common issues and recommendations for achieving compliance. Flood violations continue to cost institutions thousands of dollars of dollars every year! This session examines the requirements of the Interagency Final Rules including:
  • The exemption from coverage for any structure that is part of a residential property but is detached from the primary residential structure and does not serve as a residence.
  • The revised Flood Hazard notice.
  • The requirement to offer the option to escrow flood insurance premiums and fees on loans outstanding as of January 1, 2016.
  • The revisions to the rules for force-placing flood insurance; and
  • The requirements that lenders accept private flood insurance.

UDAAP & Junk Fees - Maureen E. Carollo
The regulators have been keenly watching the various fees that have been part of the residential lending industry and clearly disclosed for decades and they have suddenly decided that many of these fees are now "junk" fees and are now predatory and fall into the dreaded UDAAP category. We will discuss and dissect this group of fees and identify why these are giving the regulators so much heartburn and what you can do to clearly disclose them more clearly to ensure that they will be understood by your customers.

1071 Update: Time to Get Serious - Kimberly Boatwright
Since the CFPB's final rule implementing Section 1071 of the Dodd-Frank Act was finalized on March 30, 2023, there have been multiple lawsuits against the legality of the CFPB's funding structure, putting Section 1071 on-hold. However, the CFPB was declared constitutional on May 17, 2024, and Section 1071 is a go!

As you're aware, implementing the changes needed to comply with Section 1071 of Regulation B will require a full compliance management program, including new policies, procedures, training, auditing, and will impact budgeting for several years. This session is designed to focus on key definitions, effective dates, and the required data fields, plus a few practical steps for implementing the new rules as efficiently as possible within your institution.

AI and Compliance: The New Frontier - Rebekah Leonard
Compliance Officers are a special and talented bunch! We sift through volumes of information, learning myriad rules and facts, then apply those facts to solving complicated compliance questions and problems.

AI / Machine Learning is doing much the same thing. Computing power is used to take tremendous amounts of data and apply it to problem solving or interpretation. With "Generative AI" this is taken a step further, with existing patterns used to create *brand new* content.

What does this mean for compliance officers? Are we going to be replaced?! NO. Human thinking and reasoning is still superior (and principled, ethical, and honorable) to computer extrapolation, but AI and Machine Learning IS a new tool that could be harnessed to help us do our jobs more efficiently and effectively... or make things miserably unfair. Truly, it could go either way, so compliance professionals need to get up to speed on the quickly evolving landscape of Artificial Intelligence, how it can be used or abused, and what regulatory authorities currently have to say about it.

Mortgage Servicing Issues - Maureen E. Carollo
"The CFPB is proposing to modify RESPA/Reg X to allow for more requirements that lenders must follow if the customer is experiencing payment difficulty, much as we did during COVID. This proposal addresses streamlining loss mitigation procedures and modifications, adding safeguards when the borrower seeks assistance, revise certain early intervention requirements and add certain communications in languages other than English so the LEP issue is being more formalized.

We will also review any of the more recent mortgage servicing enforcement actions that have occurred so that we are on top of the other concerns that the regulators are focusing on as well. "






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