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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. Get details in "A guide to implementing credit policy." Generally speaking (subject to Regulation B), business loans should be guaranteed by the principals of the borrower.

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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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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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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NY federal district court deals blow to OCC fintech charter

CFPB Monitor

The court failed to comment on the fact that the powers of national banks include “receiving deposits” and “loaning money on real and personal security” but do not give primacy to either of these powers over the other. The court’s textual analysis started with a review of the powers of national banks under the NBA.

Fintech 68
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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

Numerous regulatory resources go into detail, including fair lending videos from the FDIC and examination procedures published on the Consumer Financial Protection Bureau’s website. However, according to the FDIC , they can be deemed as such based on their information sharing practices.