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2022 Dodd-Frank Stress Test Scenarios Released

Perficient

The Office of the Comptroller of the Currency (OCC) recently released the economic and financial market scenarios that will be used in the upcoming stress tests for covered institutions. As repeated by federal bank regulators, the required economic scenarios are not forecasts. The 3-month Treasury rate increases from 0 percent to 1.5%

Capital 294
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CFPB Summer 2020 Highlights looks at consumer reporting, debt collection, deposits, fair lending, mortgage servicing, and payday lending

CFPB Monitor

The report discusses the Bureau’s examinations in the areas of consumer reporting, debt collection, deposits, fair lending, mortgage servicing, and payday lending that were completed between September 2019 and December 2019. Violations of Regulation E requirements regarding qualifying notices of EFTA errors. Fair lending.

Lending 78
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Another Maryland threat to bank partner model lending

CFPB Monitor

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. In 2016, the OCFR brought an enforcement action against CashCall, a nonbank operating a high-rate bank model program. million in penalties against CashCall.

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Food for Thought: A Policy on Credit Exceptions

Abrigo

unsecured lending is bad rather than unsecured lending should only be extended to high pass risk rated credit). The following is an example of how I would address the structural exception of non-recourse lending. Generally speaking (subject to Regulation B), business loans should be guaranteed by the principals of the borrower.

Policies 195
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CFPB Summer 2021 Supervisory Highlights looks at auto servicing, consumer reporting, debt collection, deposits, fair lending, mortgage origination and servicing, private student loans, payday lending, and student loan servicing

CFPB Monitor

Financial institutions were found to have violated Regulation E by: Failing to comply with provisional credit requirements for disputed transactions. Fair lending. Sending validation notices that did not include required information.

Lending 78
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Dear Mr./Ms. Bank Regulator

Jeff For Banks

My firm will occasionally provide feedback on correspondence to our clients'' regulators. I thought about what we should have said to the regulator, versus the sweet words I was encouraging our client to use. Below is a sample letter to your regulator, saying it like you mean it. Today we did just that. Truth is, I haven''t.

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Data-driven strategies for banks and credit unions: Start here

Abrigo

For example, say your management and board’s strategy for the upcoming year is to grow the CRE loan portfolio by 10%, and the institution needs to consider expanding into new markets to achieve this goal. Where are the majority of your borrowers and collateral located, and where should the institution concentrate its marketing efforts?

Strategy 195