On February 7, 2014, the Office of the Comptroller of the Currency (“OCC”) updated the Comptroller’s Handbook, which replaces the 1996, 1998, and 2008 versions that provided guidance for banks and thrifts. This new document explains the specific policies and procedures that will be reviewed as part of examinations, as well as information technology requirements. The updated mortgage banking handbook breaks down the areas for examination, including loan production, secondary marketing, and servicing, and it provides important information about each of these areas.
Importantly, the updated OCC handbook addresses the recent Consumer Financial Protection Bureau (“CFPB”) amendments to Regulation X and Regulation Z, as well as certain statutory and regulatory changes resulting from the Dodd-Frank Act. This update is a comprehensive update, replacing prior versions that may have been resources for banks.
The OCC’s press release included a directive called “Note for Community Banks,” which stated that the update applies to all banks engaged in mortgage banking activities. Although your financial institution may have a different regulator, it is important to identify the extent to which your policies and procedures need to be altered to comply with these updates.
Please contact Spilman or other knowledgeable counsel with questions.
Click here for the Bulletin announcement/release.
Click here for the Bulletin link.