Pennsylvania Examination Preparation

While the Pennsylvania examination is thorough, the examiners themselves tend to be helpful and take time to explain what is needed, and whether items submitted meet the requirement. In general, particularly for the first examination, the intent of the review is educational; set expectations from the department for the conduct of the licensee. 

Pennsylvania Documentation Request

The regulator requests written policies and procedures for all functional areas. It seems daunting, but these items are all part of our Compliance Package. Then, it is just a matter of extracting the correct pages from the plans.

Quality control program procedures
Written Anti-Money Laundering Program and last independent review
Ability to Repay policy and procedures
Hiring and Termination policies
Consumer Complaint Policies and Procedures
Fraud Prevention Program / Identity Theft Prevention Program
Cyber Security / Information Technology Security Policies and Procedures
Gramm-Leach-Bliley policy
Business Plan - See 
CARES Act Policies and Procedures 

​Internal/External audit procedures

This is a catch-all. Most small companies do not have an internal/external audit, although they should. We extract the following self-examination procedures which are part of various plans. 

• Compliance Audit - Loan level post-closing compliance review conducted on each loan after closing. This also functions as a Fair Lending Review.  From the Quality Control Plan
• Anti-Money Laundering Audit - Annual review of procedures to ensure documentation of compliance. From the Quality Control Plan
• Information Security Audit - Annual review of procedures and infrastructure to ensure compliance with Gramm-Leach-Bliley Safeguarding Rules. From the IT Plan
• Advertising Audit - Advertisement level review of each commercial message - From the Compliance Manual.