Forum Replies Created
-
Posts
-
Question regarding the UDAAP Procedures: Is it reasonable to think that the Operating function and the Control function can be handled by the same group, i.e. Compliance department. For example, the Repricing and Changes in Terms Checklist appears to be a function that would best fit the Compliance dept. in our bank. Would we be criticized by examiners if the compliance dept. handled both Operating and Control functions and then our internal audit department handled the audit function?
I have my first UDAAP Alliance meeting on the calendar to occur next Thursday, the 23rd. My Alliance group is made up of the marketing department (3 members), a customer service representative, a loan officer, a collection supervisor, two audit assistants, and an HR representative. The goal is to allow each of those individuals/depts. review the checklists that Jack provided to us and tweek them to fit the needs of our bank. Once the worksheets are reviewed, we will then use those to review our existing products and services. In addition the worksheets will become part of our procedures to ensure new products/services are reviewed as well. The policy and procedures will be reviewed and tweeked as part of the Alliance and taken to Board for approval by end of March. My goal is to have everything in place and complete by end of April! Just wanted to provide some feedback on how my Alliance group is working and who is a part of it. Thanks!
First, just want to say that these materials are great! I finally had the opportunity to review today and feel that this will help me get UDAAP policies and procedures implemented at my bank without having to jump off the roof!
Just wanted to provide a few questions or comments that I had as I progressed through the material:
1. Is there a need to put a UDAAP section in other policies that reference the fact that UDAAP policies and procedures exist, once these are implemented? The act of getting a policy approved in our bank takes quite a few steps and we are beginning a new year of taking policies to board so would like to know if this is something we should build into other policies as a reference.2. Just as a comment, anytime we have a large change with policies/procedures in our bank, we have begun to setup an “Alliance” for whatever the subject matter is. This allows us to draw people in from other areas of the bank so that those areas affected are aware and take part in the change. I am leaning toward a UDAAP Alliance for this to be able to review all existing products/services! In other words, compliance is everyone’s responsibility, don’t do it alone! 🙂
3. Does anyone currently have a complaint/resolution policy/procedure that they don’t mind sharing? We have minimal procedures but I would like to have something more substantial in order to provide some consistency across all banking centers and management and would like to have this as part of this UDAAP project.
4. In the procedures, do you see the “Control” function as a Compliance function in your bank?
Thanks in advance for help and feedback!
Kelly Owsley
