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Joint Guidance Provided to Banks to Manage Risks Associated With Third-Party Relationships

Perficient

Often an organization will have a state-charted non-member bank, which has the FDIC as its primary federal regulator. The guidance emphasizes that using third parties, especially those using new technologies, may present elevated risks to banking organizations and their customers, including operational, compliance, and strategic risks.

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Great expectations: Loan review system regulations and how to adhere to them

Abrigo

WATCH Takeaway 1 Loan review officers must figure out how to adhere to the FDIC’s guidance on loan review and credit risk review systems. Takeaway 2 Examining the following objectives and evaluating your loan review system based on them can ensure regulatory compliance.

System 195
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Trade Groups Say “No Thanks” to Notion that FDIC Should Consult CFPB Before Approving Bank Mergers

CFPB Monitor

One issue raised in the RFI is “to what extent should the CFPB be consulted by the FDIC when considering the convenience and needs factor and should that consultation be formalized?”. Whether the FDIC finds these arguments persuasive is yet to be seen.

FDIC 78
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BaaS Banks Are in Time Out, and Here’s Why It’s a Big Deal

Gonzobanker

Cross River Bank recently found itself in hot water with the FDIC when the agency declared that the bank engaged in unsafe or unsound banking practices in relation to its compliance with fair lending laws and regulations, specifically the Equal Credit Opportunity Act and the Truth-in-Lending Act.

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FDIC 2018 Consumer Compliance Supervisory Highlights focuses on overdraft, RESPA, Regulation E, deferment, and finance charge calculation exam findings

CFPB Monitor

Last week, the FDIC published its Consumer Compliance Supervisory Highlights that provides observations about its consumer compliance supervision activities in 2018. The FDIC’s anonymized exam findings include: Overdraft Programs. Real Estate Settlement Procedures Act (“RESPA”) Section 8 Violations.

FDIC 60
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Another Maryland threat to bank partner model lending

CFPB Monitor

Atlanticus/Fortiva performs all of the collections, servicing, payment and remittance operations in connection with the accounts. The OCFR claims that the Bank’s failure to hold the required lending licenses makes the loans unenforceable and prohibits Atlanticus/Fortiva from collecting any amounts on the loans.

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Why banking technology makes sense – recession or not

Abrigo

But when a storm hit, limitations on the back end due to its insufficient operations technology hampered Southwest’s ability to handle the most basic customer service in that industry: getting customers safely where they needed to be. A buyer’s guide for lending software for smaller financial institutions can be helpful.