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Financial Services Law Insights and Observations

FDIC Releases Interagency Mortgage Examination Procedures

FDIC Examination Mortgage Origination Mortgage Servicing Bank Supervision

Lending

On February 25, the FDIC issued FIL-9-2014 to notify supervised institutions of new consumer compliance examination procedures for the mortgage rules issued pursuant to the Dodd-Frank Act, that took effect nearly two months ago.  FDIC examiners will use the revised interagency procedures to evaluate institutions' compliance with the new mortgage rules. The FDIC states that during initial compliance examinations, FDIC examiners will expect institutions to be familiar with the mortgage rules' requirements and have a plan for implementing the requirements. Those plans should contain “clear timeframes and benchmarks” for updating compliance management systems and relevant compliance programs. “FDIC examiners will consider the overall compliance efforts of an institution and take into account progress the institution has made in implementing its plan.”