Description
Maneuver through complex topics gracefully by exploring several key concepts that frontline personnel encounter on a daily basis.The business is the first line of defense for compliance issues. Each and every day, they interact with your customers through letters, monthly statements, over the phone, and text messages. What processes do you have in place to make sure that what they say complies with your legal and regulatory obligations? This presentation will walk through the implementation of COVID19 legal and regulatory requirements as a test case on what steps you should take to ensure the business is set up for success so your organization can reduce risk. We will walk through best practices on implementation, discuss legal cases that touch on these issues, and end with an enforcement action brought by the OCC that highlights potential pain points when implementing new laws and regulations.
Date: 2023-05-17 Start Time: End Time:
Learning Objectives
Response to COVID-19 as a Test Case for First-Line Compliance
• CFPB Bulletin 2021-02 • Addressing Housing Insecurity
• How Are You Communicating With Your Borrowers?
Policies and Procedures
• Updates to Law = Updates to Policies and Procedures
• Updates to Law = Training
Loss Mitigation and Collection Methods
• Call Strategy
• Letter Strategy
• Discussion of Hunstein v. Preferred Collection and Mgmt. Servs., Inc., 48 F.4th 1236, 1240 (11th Cir. 2022) (en banc)
• Discussion of Daniels v. Select Portfolio Servicing, Inc., 2022 WL 1639012 (11th Cir. May 24, 2022)
In the Matter of: Carrington Mortgage Services, LLC • File No. 2022-CFPB-0011
• Discussion of Enforcement Action and OCCs Finding
• Ways to Avoid Issues Highlighted by the OCC
• Lessons Learned
Question and Answer
CLE (Please check the Detailed Credit Information page for states that have already been approved) ,Additional credit may be available upon request. Contact Lorman at 866-352-9540 for further information.
Todd Domjan-PNC Bank, National Association, Joshua C. Prever – Holland & Knight LLP
