Thanks for your comment/suggestion on the procedures. We’ll certainly take a look at them and notify you and all Compliance Master Group members if we make changes. In the meantime, you may customize the procedures to fit your bank and include more information as you see fit. It is certainly reasonable to include adverse reporting requirements under 1024.35(i); if you do include this information you may also want to include the information under 1024.35(g).
In regard to your second question, you are correct unless one of the requirements in 1024.35(g) are met which includes: 1) duplicative notice of error; 2) overboard notice error; or 3) untimely notice of error. Also, read beginning on page 205-206 of the preamble linked below. It explains the CFPB’s reasoning behind the adverse information timing requirement.