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Federal banking agencies issued proposed guidance on risk management for third-party relationships

CFPB Monitor

The Federal Reserve, FDIC, and OCC have released proposed guidance for banking organizations on managing risks associated with third-party relationships, including relationships with financial technology-focused entities such as bank/fintech sponsorship arrangements. Due diligence and third-party selection. Contract negotiation.

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Enforcement Actions Against Banks Reached Record Low in 3Q

Bank Innovation

This past quarter saw the lowest number of enforcement actions against financial institutions since 2013 (though there were some prominent cases in the media spotlight that may have led observers to think otherwise.) New Haven, Conn.-based

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Independent Loan Review & Credit Risk Review System Objectives

Abrigo

This article is substantially updated from a 2013 blog post. An effective independent loan review system has always been critical for managing a financial institution’s credit risk and accurately estimating the allowance for loan and lease losses, or ALLL. It also monitors compliance with applicable regulations and laws.

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Diversity reports at two federal agencies offer glimpse of regulatory review under impending Dodd-Frank diversity standards

CFPB Monitor

In October 2013, six federal agencies proposed joint diversity standards for public comment. Despite the fact that the FDIC and OCC had taken measures to promote diversity as directed by Dodd-Frank, both reports concluded that more could be done. Final standards could be issued in the near future.

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CFPB gives boost to use of alternative data and machine learning

CFPB Monitor

The letter was conditioned on Upstart’s agreement to a model risk management and compliance plan that required it to analyze and address risks to consumers, and assess the real-world impact of alternative data and machine learning. The Bureau issued its first (and so far only) no-action letter in September 2017 to Upstart Network Inc.

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CFPB issues final diversity and inclusion standards

CFPB Monitor

The other agencies were the OCC, Fed, FDIC, NCUA and SEC. While the final standards generally track the standards proposed by the agencies in October 2013, they provide some clarifying language in response to public comments. For a more detailed discussion of the final standards, see our legal alert.

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Bankers: Is your strategy the same as your competitor?

Jeff For Banks

It is annual report season, meaning publicly traded financial institutions are finalizing their 2013 numbers and submitting their 10k''s to the Securities and Exchange Commission (SEC). The Bank also offers wealth management and trust services. In preparation for meetings, I frequently read 10k''s.

Strategy 101