Some Additional Insight into the OTS Exam Procedures
I’m sure you are all aware of the big announcement from the OTS this month regarding the exam procedures for FACT Act Red Flag and Address Discrepancy. Nothing really earth-shattering came out in the announcement itself, the exam procedures outlined by the OTS follow the regs right down the line, just as they’ve been describing all along. What is interesting about the announcement is that it is a not-so-subtle reminder that the November 1st deadline and all the newly required policy, board review, and audit trail are very real.
When thinking about this, an old movie quote comes to mind: “It’s not what you know, it’s what you can prove.” When talking to banks about some of the compliance strategies they are planning to implement, I wonder how it will shake out when the auditors come around.
For example, for Section 315, which requires a belief of true identity to be formed when a credit report has a conflicting address with a consumer application. How do you provide an audit trail with a manual verification process? It can be done I’m sure — but how easily? With an automated solution, the audit trail part couldn’t be simpler. System logs reveal every explicit detail of every factor associated with a question of identity and address change, and how it was handled with an empirically driven, risk-based approach with a push of a button. Okay, maybe two or three buttons — but you get the point!
Stay tuned as we move down the stretch…