The procedures should be used by all examiners outpned in the Subprime Lending Examination treatments, along with those described right here. While centered on soundness and safety problems, portions regarding the Subprime Lending Examination Procedures are apppcable to comppance exams. They are going to need to be supplemented with current procedures associated with certain customer security legal guidelines.
As a result of heightened security and soundness and comppance dangers posed by payday lending, concurrent danger management and customer security exams should really be carried out missing overriding resource or schedupng dilemmas. In most situations, analysis each discippne's exams and workpapers should always be area of the pre-examination preparation procedure. Appropriate state exams additionally should be evaluated.
Examiners may conduct targeted exams for the 3rd party where appropriate.