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MMC Fair Credit Reporting Act Exam Procedures.doc

By Curtis Tucker,2014-02-12 13:33
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MMC Fair Credit Reporting Act Exam Procedures.doc

    Multistate Mortgage Cmmittee

    Fair Credit Reporting Act

    Examination Procedures

    Examination Procedures

     Y N [Document supporting evidence noting determinations and findings made]

    1 Coordinate compliance examination activities with other members of

    the examination team and the examiner-in-charge (EIC). Emphasize

    identifying violations of law and regulation; integrate those findings

    with the examination; and conclude on management's compliance

    with laws and regulations.

    Examiner Notes:

    2 Review and evaluate the adequacy of policies, procedures, and

    internal controls to ensure the identification of applicable applicants

    and compliance with the requirements of the FCRA.

    Examiner Notes:

    3 Discuss with management the institution's activities related to

    collecting, reporting, supplying, and using credit information, and

    determine whether:

    a. The institution uses credit information obtained from credit bureaus or other outside sources in evaluating consumer credit

    applications; and

    b. The institution's activities make it subject to the consumer

    reporting agency requirements of the FCRA.

    Examiner Notes:

    4 If the institution uses information from credit bureaus or other

    outside sources in evaluating consumer credit applications,

    coordinate the testing for compliance with the testing of rejected

    applications, and determine that the institution makes the disclosures

    required by FCRA as users of credit information.

    Examiner Notes:

    5 Conclude whether the institution is adequately complying with the

    FCRA. If not, ascertain whether the conclusion of noncompliance is supported by adequate documentation of the specific

    noncompliance.

    Examiner Notes:

    1 of 2

    Multistate Mortgage Cmmittee

    Fair Credit Reporting Act

    Examination Procedures

    Examination Procedures

     Y N [Document supporting evidence noting determinations and findings made]

6 Utilize discussions with managers, as needed, to gather information

    and discuss procedures and practices followed by institution

    personnel to ensure compliance with laws and regulations.

    Examiner Notes:

7 Discuss items of concern, scope of work performed, and conclusions with the EIC.

    Examiner Notes:

8 Organize and compile, if necessary, violations of law and regulation into a Violation Summary Sheet.

    Examiner Notes:

    2 of 2

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