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Food for Thought: A Policy on Credit Exceptions

Abrigo

As the FDIC said recently: Exceptions to policy should be few in number and properly justified, approved, and tracked. If actual practices vary materially from the written guidelines and procedures, the source of this discrepancy should be identified, and either actual practices or the written policy should be changed.

Policies 195
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Consumer Lending Compliance: Hot-Button Issues to Monitor

Abrigo

Consumer lending compliance — like other aspects of enterprise risk management at financial institutions — saw a huge impact from the COVID-19 pandemic. Examiners, therefore, will routinely consider whether consumer lending underwriting and pricing guidelines, policies, and procedures comply with these requirements.