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Compliance changes to watch in 2023

Independent Banker

The FDIC approved a final rule to increase initial base deposit insurance assessment rates by 2 basis points until the Deposit Insurance Fund (DIF) achieves the FDIC’s long-term goal of a reserve ratio of 2% of insured deposits. The FDIC’s long-term goal for the reserve ratio of insured deposits. Source: FDIC.

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Food for Thought: A Policy on Credit Exceptions

Abrigo

Path to removal – Sometimes an exception is like the Hotel California – you can check out anytime you like, but you can never leave. This is particularly true of credit exceptions related to account management (e.g., As the FDIC said recently: Exceptions to policy should be few in number and properly justified, approved, and tracked.

Policies 195
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Signaling Caution

Independent Banker

Regulators warn once again about rising CRE concentrations and risks. Obviously these local lenders took notice when the Federal Reserve, the FDIC and the Office of the Comptroller of the Currency recently issued a joint statement pointing out increased risks in CRE lending. Smart for California.

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Preparing for Section 1071

Abrigo

In 2011, the CFPB interpreted Section 1071 to mean that obligations for financial institutions to collect, maintain, and submit data “do not arise until the [CFPB] issues implementing regulations and those regulations take effect.” Those implementing regulations were coming. California Reinvestment Coalition v.

Lending 195