What kinds of concerns are financial institutions and creditors expressing about the FACT Act?
A. Now that the Office of Thrift Supervision has unveiled its FACT Act Red Flags examination procedures, financial institutions are getting the first concrete look at what can be expected during an examination. With roughly a month to go before the Nov. 1 compliance deadline, many financial institutions are realizing that they need to expedite implementation of the necessary policies and procedures. Many of the institutions we’ve been talking with have been counting on some flexibility in the degree to which they comply with the deadline, but based on the OTS examination procedures, Nov. 1 means Nov. 1. OTS audit requirements state that Board of Director meeting minutes prior to Nov. 1 must indicate a board’s approval of the financial institution’s FACT Act compliance program. This likely means that all system changes, policies, procedures and training programs must also be in place by the deadline. Realizing that the Nov. 1 compliance date is just around the corner, many teams are put
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