CFPB Monitor

DECEMBER 13, 2018

The CFPB has issued a new annual report covering its fair lending activities during 2017. Since Mick Mulvaney did not become Acting Director until the end of November 2017, the fair lending activities described in the report largely took place under former Director Cordray’s leadership.

Lending 92

Lending Report Regulation Leadership 92

Abrigo

AUGUST 8, 2021

Independent Loan Review Systems in Banking Banking regulators have outlined expectations for effective, independent loan review and credit risk review. . The change reflects regulators’ expectations that financial institutions will develop loan review or credit review systems tailored to their specific risks and circumstances.

System 195

System Lending Policies Regulation 195

CFPB Monitor

MAY 7, 2020

The CFPB’s annual fair lending report covering its 2019 activities is scheduled to be published in tomorrow’s Federal Register. The Bureau states that an area of innovation that it is monitoring for fair lending and credit access issues is “artificial intelligence (AI), and more specifically, machine learning (ML), a subset of AI.”

Lending 78

Lending Report FDIC Policies 78

CFPB Monitor

JUNE 21, 2021

As previously reported , the bill signed into law by President Biden on June 17, 2021 to create the Juneteenth National Independence Day actually results in an important change under the Truth in Lending Act (TILA) and Regulation Z. Industry members likely will find the initial guidance to be unhelpful.

Lending 78

Lending Compliance Regulation National 78

CFPB Monitor

JUNE 30, 2022

Of special note, the OCC also believes compliance risk is “heightened” for Bank Secrecy Act/Anti-Money Laundering (BSA/AML) and Office of Foreign Assets Control (OFAC) compliance because of world events and compliance staffing concerns. BSA/AML Compliance Risks. Cybersecurity Risks.

Compliance 78

Compliance Fraud Technology Operations 78

CFPB Monitor

JUNE 14, 2021

Two leaders of the CFPB’s Fair Lending Office – Patrick Ficklin, Fair Lending Director, and Charles Nier, Senior Fair Lending Counsel – recently published an article advocating for broader use of special purpose credit programs (“SPCPs”) by creditors.

Lending 78

Lending Regulation Study Washington 78

Abrigo

APRIL 21, 2023

Focus loan reviews on risk in the portfolio Continuous loan review monitoring helps banks and credit unions ensure credit review systems support safe and sound lending. discussed how they use continuous monitoring in their efforts to ensure safe and sound lending practices.

Lending 195

Lending Risk Management Software System 195

CFPB Monitor

DECEMBER 13, 2021

The report discusses the Bureau’s examinations in the areas of credit card account management, debt collection, deposits, fair lending, mortgage servicing, payday lending, prepaid accounts, and remittances that were completed between January 2021 and June 2021. Fair lending. Key findings by CFPB examiners are described below.

Lending 78

Lending Cards Regulation Payments 78

CFPB Monitor

JUNE 14, 2021

The new law became effective immediately upon signing notwithstanding the authority it gives the Illinois Department of Financial and Professional Regulation (“IDFPR”) to adopt rules “consistent with [the] Act.”. Proposed Regulations. The IDFPR has proposed regulations to implement the Act.

Illinois 78

Illinois Regulation Report Lending 78

PYMNTS

APRIL 10, 2017

The lead regulator for U.S. The Office of the Comptroller of the Currency accused Wells Fargo of an “extensive and pervasive pattern” of discriminatory and illegal lending practices for years. Notably, most of the cases referred to by the OCC had already been announced and, in some cases, were over a decade old.

Regulation 100

Regulation California Community Bank Cards 100

PYMNTS

FEBRUARY 14, 2018

Wells can still lend and take deposits. In reference to corporate governance, Wells has two months to boost board oversight and compliance efforts. The move is unprecedented, as the Fed has never before placed limits on how large a company can get.

Regulation 100

Regulation Conference Compliance Lending 100

CFPB Monitor

JULY 8, 2019

The CFPB’s annual fair lending report covering its 2018 activities was published in today’s Federal Register. In addition to discussing the symposium and Data Point report in the section on “Access to Credit,” the new fair lending report discusses conducting supervisory reviews of alternative credit scoring models.

Lending 60

Lending Report Policies Compliance 60

Abrigo

JUNE 5, 2023

In addition, even before the recent banking troubles, regulators have emphasized the financial institution’s responsibility to provide leaders with information on key areas of planning, operations, and risk management. Regulators review them to assess safety and soundness.

Report 195

Report Risk Management Capital Data 195

CFPB Monitor

JANUARY 28, 2021

As a result of the PAs, the Bureau initiated significantly more fair lending supervisory events during the period covered by the report than during the prior reporting period. During the period covered by the report, the Bureau filed one fair lending public enforcement action and referred three ECOA matters to the DOJ.

Report 78

Report Leadership Lending Regulation 78

CFPB Monitor

MARCH 16, 2021

Under the leadership of Acting CFPB Director Dave Uejio, the Bureau issued an interpretive rule on March 9, 2021 clarifying that the prohibition against sex discrimination under the Equal Credit Opportunity Act (“ECOA”) and Regulation B includes sexual orientation and gender identity discrimination.

Regulation 78

Regulation District of Columbia Georgia Policies 78

CFPB Monitor

NOVEMBER 22, 2022

In particular, the report’s recommendations deserve attention because they are likely to influence future actions by the federal banking regulators and the CFPB. (The The report attributes the risk that such schemes will arise to bank/fintech relationships that “lack proper regulatory oversight or principles for responsible lending.”

Fintech 78

Fintech Report Data Lending 78

Jeff For Banks

APRIL 4, 2024

Such as direct lending funds, and insurance companies. Shadow Banking refers to banking-like operations that take place outside of the mainstream banking industry. Shadow bank lending is similar to bank lending but is not subject to the same regulations, and compensating deposit balace requirements.

Banking Trends 115

Banking Trends Trends Millennials Oregon 115

CFPB Monitor

MAY 12, 2015

In a new compliance bulletin ( Bulletin 2015-02 ), the CFPB “reminds” creditors of their obligation not to discriminate against applicants because their income includes vouchers from the Section 8 Housing Choice Voucher (HCV) Homeownership program.

Compliance 60

Compliance Regulation Policies Training 60

CFPB Monitor

MAY 3, 2016

The CFPB has issued a report covering its fair lending activities during 2015. The report states that in 2015, CFPB fair lending supervisory and public enforcement actions required institutions to provide approximately $108 million in remediation. It also notes that in 2015, the CFPB referred 8 matters to the Department of Justice.

Lending 60

Lending Report Compliance Meeting 60

Abrigo

JANUARY 24, 2021

In addition, even though those who long sought a streamlined process for loans of $150,000 or less loans often referred to it as “blanket forgiveness” or “automatic forgiveness,” Form 3508S has important requirements for the loan to be fully forgiven. CRE Lending. Lending & Credit Risk. CRE Lending. CRE Lending.

Lending 195

Lending Risk Management Management Payments 195

CFPB Monitor

APRIL 29, 2015

The CFPB has issued a fair lending report covering its fair lending activities during 2014. The report states that in 2014, CFPB fair lending supervisory and public enforcement actions required institutions to provide approximately $224 million in remediation.

Lending 60

Lending Report Policies Compliance 60

Abrigo

DECEMBER 30, 2019

Institutions must create a strong culture of compliance. Creating a Culture of Compliance. One of the more important takeaways from 2019 is that all institutions, regardless of size or risk profile, must have a strong culture of compliance, as directed by FinCEN’s advisory in 2014. Looking back to strengthen your BSA program.

Training 195

Training Compliance Leadership Fraud 195

CFPB Monitor

FEBRUARY 26, 2019

The FTC has sent its annual letter to the CFPB reporting on the FTC’s activities related to compliance with the Equal Credit Opportunity Act and Regulation B. Interagency fair lending task force. By way of example, the FTC references a blog post about the need to provide financial education to servicemembers.

Report 87

Report Study Analytics Lending 87

PYMNTS

JUNE 11, 2018

Change across the regulatory compliance landscape is de rigueur, and global in scope. Also in Australia, and apropos to small business lending, Prospa delayed issuing additional shares on the country’s stock exchange, in part due to pressure from financial services regulators in that country. Closer to home, in the U.S.,

Regulation 100

Regulation Community Bank Lending Industry 100

CFPB Monitor

FEBRUARY 10, 2021

On January 26, 2021, the FTC sent its annual letter to the CFPB reporting on the FTC’s activities related to the Equal Credit Opportunity Act (“ECOA”) and Regulation B. The FTC has authority to enforce the ECOA and Regulation B with respect to nonbank financial service providers within its jurisdiction.

Report 78

Report New York City Lending Regulation 78

CFPB Monitor

FEBRUARY 24, 2020

FTC has sent its annual letter to the CFPB reporting on the FTC’s activities related to compliance with the Equal Credit Opportunity Act and Regulation B. The FTC continues to be a member of the Interagency Task Force on Fair Lending along with the CFPB, DOJ, HUD, and the federal banking agencies.

Report 78

Report Policies Big Data Regulation 78

CFPB Monitor

MAY 3, 2016

As we have reported , the CFPB issued a final rule, which became effective on January 1, 2016, revising the definitions of “small creditor” and “rural areas” under Regulation Z of the Truth in Lending Act (TILA). The factsheet and chart can be found under “Quick references” on the CFPB Compliance & Guidance page, at this link.

Resources 60

Resources Compliance Regulation Lending 60

CFPB Monitor

DECEMBER 19, 2019

The OCC and FDIC have issued a joint proposal to revise their regulations implementing the Community Reinvestment Act (CRA). Although the Federal Reserve, OCC and FDIC, are the primary CRA regulators, the Fed did not join the proposal and presumably will issue a separate proposal. Our thoughts.

FDIC 78

FDIC Regulation Community Retail 78

CFPB Monitor

JULY 29, 2022

The action is notable in that it is the first time the FTC has brought an action under the Military Lending Act (“MLA”). A judgment in the amount of $24 million is suspended pending Harris Jewelry’s compliance with the terms of the stipulated settlement order.

National 78

National Retail Regulation New York 78

Abrigo

APRIL 7, 2022

Instead, remember that if your institution’s process is reasonable, defensible, and based on accurate and available data , compliance will not be an issue. Once factors like the economy, new regulations, management changes, or even natural disasters are factored in, a greater allowance may be necessary.

Policies 195

Policies Data Examples Lending 195

CFPB Monitor

MAY 22, 2020

The Federal Reserve, OCC, FDIC, and NCUA have issued “ Interagency Lending Principles for Offering Responsible Small-Dollar Loans.” In that statement, the agencies indicated that they were “working on future guidance and lending principles for responsible small-dollar loans.”.

FDIC 78

FDIC Policies Lending Guidelines 78

Abrigo

JULY 12, 2021

While many of these extremists (also referred to as extreme right-wing (ERW) terrorism) are loan wolves, it is understood that there are also small to medium sized organizations, some transnational. One important step toward further global compliance for the U.S. BSA Rules and Regulation. Lending & Credit Risk.

Training 195

Training Policies United States Report 195

CFPB Monitor

MAY 3, 2021

Since the non-bank entity frequently is a fintech, these arrangements often are referred to as bank-fintech partnerships or marketplace lending arrangements. These speakers consistently conflated payday lending and bank-fintech partnership lending, and ignored correction of this mis-characterization by other witnesses.

North Carolina 60

North Carolina Lending National District of Columbia 60

CFPB Monitor

OCTOBER 4, 2022

A previous version of these procedures referenced the Regulation Z definition of “private education loans” which differs from the Truth in Lending Act definition.

Policies 146

Policies Compliance Payments Training 146

CFPB Monitor

MARCH 12, 2019

Several Democratic members also criticized the Bureau’s continued employment of Eric Blankenstein as Policy Associate Director of the Bureau’s Office of Supervision, Enforcement, and Fair Lending. In response to a question from Senator Doug Jones regarding the Bureau’s use of the disparate impact theory in future fair lending cases, Ms.

Lending 68

Lending Analysis Compliance Policies 68

Independent Banker

SEPTEMBER 25, 2014

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. By Vanessa Drucker.

Community Bank 70

Community Bank Compliance Risk Management Community 70

CFPB Monitor

OCTOBER 27, 2022

GAP insurance generally refers to third party insurance purchased by a consumer in a separate transaction from the actual vehicle purchase, typically as added coverage to their auto insurance. 10 USC § 987(i)(6). 10 USC § 987(i)(6).

California 148

California Security Regulation United States 148