Case Study 3: Consumer Correspondence to Meet Regulatory Requirements
A regional bank found it challenging to stay abreast of changing regulatory requirements for correspondence delivery to consumer credit customers. The process of complying with the regulatory requirements around timely mailing, disclosures and imaging was a manual process. The bank needed to find a dynamic solution that could quickly adapt to changes and meet regulatory requirements.
The bank needed to meet disclosure and delivery requirements for copies of appraisals and other written valuations as documented in Regulation B Amendment and the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank or DFA) and enforced by the Consumer Financial Protection Bureau (CFPB). In addition, new rules combined certain disclosures required under the Truth in Lending Act (TILA) and the Real Estate Settlement Procedures Act (RESPA) that consumers receive in applying for and closing on residential mortgage loans. The new disclosures are generally referred to as the ‘combined’ or ‘integrated’ disclosures (RESPA/TILA Disclosures). The cost, time and internal human resources needed to meet the requirements could not be performed timely and would come at a high cost. The bank could not risk being non-compliant with the regulations and turned to Dataline for a solution.
Develop an automated correspondence solution that met the needs of the regional bank and also met regulatory requirements set forth by the federal agencies. The bank sends data about clients and their consumer loans to Dataline and Dataline takes responsibility for generating all correspondence and disclosures required.
- The automated process performs real-time web service calls to the regulatory agencies to pull the latest data and information necessary to meet some of the regulatory compliance requirements
- Automated business rules determine the appropriate disclosures each client should receive based on client and account characteristics
- Electronic images of the correspondence and disclosures for each client are captured at the time of print to satisfy audit requirements for copies and proof of disclosures
- The solution is highly configurable so that as disclosure requirements change, updates can be made easily and applied quickly to meet new regulatory requirements for correspondence and/or disclosure notices