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1 · Data
Source
Scope
2 · Steps
Rules
APR disclosure accuracy
Rules
Adverse action notice timeliness
Rules
Error resolution timeliness
Rules
Regulation Z advertising · deception standard
Workflow
Impact assessment
Workflow
Review draft disclosures
Workflow
Capture page
Workflow
Check Regulation Z advertising
Workflow
Check deception standard
Workflow
Draft determination
Workflow
Pull sample
Workflow
Test samples
Workflow
Validate remediation
Workflow
Request data
Workflow
Validate population
Workflow
Draft workpaper
Workflow
Crawl merchant sites
Workflow
Select sample
Workflow
Recalculate APR
Workflow
Calculate days to notice
Workflow
Calculate business days
Workflow
Full policy scope reviewed
Workflow
Regulatory applicability reviewed
Workflow
Regulation B deep dive completed
Workflow
Disposition recommendations completed
Workflow
Redline document completed
Rules
For a sample of loans originated in the quarter, confirm each disclosure labels the APR and shows it prominently, then recompute the APR from the note and compare. · 12 CFR 1026.17(a), 1026.18(e), 1026.22(a)
For every adverse action in the quarter, count the days from the start of the clock (the completed application, or the adverse action on an incomplete application) to the notice, and flag any over 30. · 12 CFR 1002.9(a)(1)
For every error claim closed in the quarter, check the decision and result notice met the deadlines, and that provisional credit was given on time when the investigation ran past 10 business days. · 12 CFR 1005.11(c)(1), (c)(2)
Triggering term stated; downpayment, terms of repayment or annual percentage rate not located · 12 CFR 1026.24(d)(1)(i)-(iv), (d)(2)(i)-(iii)
Rate of finance charge not stated as an "annual percentage rate", or rate increase not stated · 12 CFR 1026.24(c)
Terms not actually arranged or offered by the creditor · 12 CFR 1026.24(a)
Required terms not clear and conspicuous (e.g. a footnote not located) · 12 CFR 1026.24(b)
Open-end plan: promotional or deferred-interest terms · 12 CFR 1026.16(a), (b), (g), (h)
Approval, availability or credit-check statement: review under the deception standard · 15 U.S.C. 45; 12 U.S.C. 5531, 5536
Not flagged: "no downpayment" or "$0 down" alone, or a repayment period with no amount · Supplement I to part 1026, comment 24(d)(1)
3 · Cadence
4 · Creates
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