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

Abrigo

Systems may include components that are independent of the lending function or may place some reliance on loan officers. To make the workforce shortage even more critical, there is no real certification or formal training program for loan reviewers yet.

System 195
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FDIC 2018 Consumer Compliance Supervisory Highlights focuses on overdraft, RESPA, Regulation E, deferment, and finance charge calculation exam findings

CFPB Monitor

Last week, the FDIC published its Consumer Compliance Supervisory Highlights that provides observations about its consumer compliance supervision activities in 2018. The FDIC’s anonymized exam findings include: Overdraft Programs. Real Estate Settlement Procedures Act (“RESPA”) Section 8 Violations.

FDIC 60
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FDIC Releases Revised MLA Exam Procedures and Sets Supervisory Expectations

CFPB Monitor

On October 17, the FDIC released revised interagency Military Lending Act (MLA) examination procedures for use in connection with consumer credit transactions occurring on or after October 3, 2016. The FDIC also provided guidance on its initial supervisory expectations for examinations relating to MLA compliance.

FDIC 60
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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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Preparing your financial institution to manage loan workouts, loan modifications

Abrigo

Overall, FDIC-insured commercial banks and savings institutions aren’t seeing dramatic increases in net charge-offs ( Chart 1 ) or rates related to declining asset quality ( Chart 2 ), such as past-due rates and rates for non-current loans. Add training on loan modifications and workouts. Construction Lending. watch webinar.

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CFPB and federal banking agencies issue RFI on the use of artificial intelligence by financial institutions

CFPB Monitor

In what could be an important step towards needed regulatory updating to accommodate the growing use of artificial intelligence (AI) by financial institutions, the CFPB, FDIC, OCC, Federal Reserve Board, and NCUA issued a request for information (RFI) regarding financial institutions’ use of AI, including machine learning (ML). Fair lending.

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Are de novos making a comback?

Abrigo

The FDIC paper The Entry, Performance, and Risk Profile of De Novo Banks published in April 2016 reports that the number of de novo bank failures and acquisitions annually has drastically declined since 2010, primarily due to the fact that new bank formations have become nearly inexistent. Reduced the de novo period from 7 years to 3 2.