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FDIC Consumer Compliance Supervisory Highlights looks at unauthorized EFTs, overdraft programs, re-presentment of unpaid transactions, and fair lending

CFPB Monitor

The FDIC has issued the March 2022 edition of Consumer Compliance Supervisory Highlights which includes a description of some of the most significant consumer compliance issues identified by FDIC examiners during consumer compliance examinations conducted in 2021. Re-presentment of unpaid transactions.

FDIC 78
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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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Transaction Accounts: Analyzing Deposit Stickiness in the Current Interest Rate Environment

Perficient

Retail banks respond to the Federal Reserve’s short-term interest rate adjustments with corresponding changes in lending and deposit rates. Presented graphically below, the reader can see the significant decline in the bank’s transaction account balances during the time period analyzed.

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Another Maryland threat to bank partner model lending

CFPB Monitor

A Maryland administrative action recently removed to the state’s federal district court illustrates how Maryland law continues to present challenges for the bank partner structure used by many lenders. The new Maryland matter demonstrates that participants in bank model programs continue to face state licensing threats.

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CECL implementation: Survey shows where peers are as 2023 nears

Abrigo

The Q1 2023 compliance date is near for smaller SEC-reporting financial institutions and private or not-for-profit banks and credit unions, and progress is decidedly mixed, according to the Abrigo 2022 CECL Survey. Banks regulated by the Federal Reserve, the OCC, or the FDIC made up the bulk of institutions represented by survey-takers (73%).

Survey 195
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Pulling Off Inside Jobs

Independent Banker

Saving money by conducting inside risk management and compliance reviews. As a group, community banks spend substantial funds hiring outside consultants to help with various management functions, and a substantial share of dollars are spent to help oversee their risk management and compliance activities. 73% for compliance audits.

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Banking Regulators Issue Exemption from CIP Requirements for Premium Finance Loans

CFPB Monitor

1010.100(d) — and their subsidiaries which are subject to the jurisdiction of the OCC, Federal Reserve, FDIC, or NCUA. corporations, partnerships, sole proprietorships, and trusts) to facilitate the purchases of property and casualty insurance policies, otherwise known as premium finance loans or premium finance lending.