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Banking Third Party Risk Management Requirements are a Big and Expensive Ask

Celent Banking

Institutions are paying three times as much as their third party to complete on this exercise. The FDIC expresses best the sentiment of worldwide regulators: “A bank’s use of third parties does not relinquish responsibility… but holds it to the same extent as if the activity were handled within the institution."

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Food for Thought: A Policy on Credit Exceptions

Abrigo

As the FDIC said recently: Exceptions to policy should be few in number and properly justified, approved, and tracked. Generally speaking (subject to Regulation B), business loans should be guaranteed by the principals of the borrower. Get details in "A guide to implementing credit policy."

Policies 195
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OCC issues proposed “true lender” rule

CFPB Monitor

24, 1464(c), and 371, respectively) that allow national banks and federal savings associations to extend credit do not indicate how to determine when a bank has exercised such authority and, rather than its relationship partner, has made a loan. Presumably, we will soon see a proposed “true lender” rule from the FDIC.

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NY federal district court deals blow to OCC fintech charter

CFPB Monitor

The OCC also argued that the NYDFS’s claims were untimely because it can no longer challenge the OCC’s long-standing regulation (12 C.F.R. According to the OCC, the regulation represents a reasonable interpretation of ambiguous language in the NBA. e)(1)) interpreting the term “business of banking” in the NBA.

Fintech 68
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The Current Banking Crisis – 10 Not So Apparent Lessons

South State Correspondent

Now, customers and analysts will pay more attention to Loans + Securities-to deposit ratio. Instead of just looking at LTD, investors, and depositors, will now look at loan plus securities to total deposits. Higher cash holdings will now be a demarcation of credit quality. These inflows help mitigate a run-in-progress.

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Fraud prevention and detection: Empowering clients through education

Abrigo

Takeaway 2 Client fraud education at financial institutions should include takeaways that explain how to protect themselves from phishing and tips for staying secure online. While fraud detection software and robust security measures are essential, educating clients on fraud prevention is equally important.

Fraud 195
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Consumer Lending Compliance: Hot-Button Issues to Monitor

Abrigo

Major consumer loan compliance regulations. Major consumer loan compliance regulations cover everything from taking applications and approving or rejecting the credit to collecting payments and reporting to the government on various aspects of the loans. Regulation Z, which implements the Truth in Lending Act (TILA).