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Federal banking regulators issue statement on loan reference rates and advise prompt transition from LIBOR

CFPB Monitor

The Fed, FDIC, and OCC have issued a “ Statement on Reference Rates for Loans ” that addresses replacement rates for the London Inter-Bank Offered Rate (LIBOR). The agencies stress that banks should include fallback language that provides for the use of a “robust fallback rate” if the initial reference rate is discontinued.

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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. Fair lending.

FDIC 78
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Trade Groups Say “No Thanks” to Notion that FDIC Should Consult CFPB Before Approving Bank Mergers

CFPB Monitor

One issue raised in the RFI is “to what extent should the CFPB be consulted by the FDIC when considering the convenience and needs factor and should that consultation be formalized?”. Whether the FDIC finds these arguments persuasive is yet to be seen.

FDIC 78
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Great expectations: Loan review system regulations and how to adhere to them

Abrigo

Scope in loan reviewing Loan review systems defined The terms "loan review system" or "credit risk review system" refer to the responsibilities assigned to various areas such as credit underwriting, loan administration, problem loan workout, or other areas.

System 195
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OCC and FDIC issue proposed rules to undo Madden

CFPB Monitor

The OCC and FDIC issued proposed rules this week intended to eliminate the uncertainty created by the Second Circuit’s decision in Madden v. Comments on the FDIC’s proposal must be submitted no later than 60 days after the date the proposal is published in the Federal Register. Midland Funding. 85 [or 12 U.S.C

FDIC 78
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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). 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."

Policies 195
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Community Bank Outlook: Challenges and Opportunities in 2021 and Beyond

Abrigo

Community bank” typically refers to financial institutions under $10 billion in assets and a focus on their local communities, although there are no explicitly stated criteria. according to FFIEC and FDIC data. according to FFIEC and FDIC data. Community banks are critical to ag lending and small business lending.