CFPB Monitor

AUGUST 20, 2020

federal and state financial institution regulators have taken meaningful, proactive steps to acknowledge financial inequality issues, reach out to traditionally underserved populations to expand access to credit, and further protect consumers from discrimination. This blog post contains a summary of those efforts.

Regulation 78

Regulation FDIC Community Lending 78

Jeff For Banks

AUGUST 2, 2014

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. Warm Regards, Schmidlap National Bank.

Regulation 93

Regulation DC FDIC Analytics 93

CFPB Monitor

JANUARY 19, 2022

federal district court in December 2020 seeking to block the OCC from granting a national bank charter to Figure Technologies Inc. The lawsuit represented the CSBS’s third challenge to the OCC’s authority to issue special purpose national bank (SPNB) charters to non-depository fintech companies or to uninsured deposit-taking fintechs.

Technology 78

Technology National FDIC Fintech 78

Abrigo

JUNE 2, 2021

The guidance emphasizes a risk-focused approach to examinations and refocuses the regulators to scope each exam according to the unique financial institution, not to use a one-size-fits-all approach. The following six areas are critical when developing your exam planning: BSA/OFAC Policy integration. BSA Rules and Regulation.

How To 195

How To Training Compliance Policies 195

CFPB Monitor

APRIL 22, 2021

The agencies are the Comptroller of the Currency, Farm Credit Administration, FDIC, Federal Reserve Board, and National Credit Union Administration (Agencies). making, increasing, extending or renewing a loan), the lender must review the policy to determine if it meets the mandatory purchase criteria.

Policies 60

Policies Compliance Meeting Regulation 60

CFPB Monitor

APRIL 13, 2022

A report recently issued by the Government Accountability Office titled “ Banking Services: Regulators Have Taken Actions to Increase Access, but Measurement of Actions’ Effectiveness Could Be Improved ,” strongly suggests that banks and credit unions are unlikely to increase their small-dollar lending as consumer advocates contend.

Report 78

Report Lending FDIC Regulation 78

CFPB Monitor

OCTOBER 1, 2018

1010.100(d) — and their subsidiaries which are subject to the jurisdiction of the OCC, Federal Reserve, FDIC, or NCUA. corporations, partnerships, sole proprietorships, and trusts) to facilitate the purchases of property and casualty insurance policies, otherwise known as premium finance loans or premium finance lending.

Regulation 60

Regulation FDIC Policies Compliance 60

PYMNTS

DECEMBER 18, 2018

As well, the form has a long history of transmitting national values and providing cultural, political and even economic education — one need only dig deep into the comic scene during World War II to understand that. We hope this comic book helps illustrate the importance of regulations and compliance professionals around the globe.”.

Compliance 152

Compliance Fraud Security FDIC 152

Jeff For Banks

JUNE 4, 2018

"The FDIC recently has observed instances of liquidity stress at a small number of insured banks." So opened the Summer 2017 FDIC Supervisory Insights issue. Regulators and consultants promulgate this untruth. He was confident in his bank's liquidity position, but felt regulators could artificially create a liquidity problem.

FDIC 60

FDIC System Regulation Conference 60

CFPB Monitor

NOVEMBER 29, 2021

Federal banking regulators have been busy in this space. Accordingly, “it is important that [the Agencies] provide coordinated and timely clarity where appropriate to promote safety and soundness, consumer protection, and compliance with applicable laws and regulations, including [AML] and illicit finance statute and rules.”

Compliance 78

Compliance cryptocurrency Regulation FDIC 78

CFPB Monitor

JANUARY 19, 2015

Section 342 of Dodd-Frank directs each of the federal financial regulatory agencies to create an Office of Minority and Women Inclusion (OMWI) to oversee diversity efforts at the agencies, and further, to develop standards for assessing diversity policies and practices at regulated financial entities.

FDIC 60

FDIC Report Policies Regulation 60

Independent Banker

SEPTEMBER 25, 2014

The better prepared, the less likely they are to run afoul of the continually shifting regulations. Regulators and industry consultants agree that community banks are generally doing a great job handling their regulatory oversight and requirements. Be aware of existing or emerging risk concerns. in Kent, Ohio.

Compliance 101

Compliance Regulation Community Bank Community 101

PYMNTS

FEBRUARY 19, 2019

banking industry is in flux, largely thanks to federal policy that has made it easier (and faster) for institutions to merge. Reports said Powell noted that looser community bank regulations may help keep branches open. . making it one of the nation’s first new community banks in years.

Marketing 108

Marketing Community Community Bank Industry 108

CFPB Monitor

SEPTEMBER 9, 2020

Ballard Spahr LLP has submitted a comment letter to the OCC in support of its proposed rule , “National Banks and Federal Savings Associations as Lenders” (the “Proposed Rule”). Three virtually identical Federal Interest Statutes govern interest that may be charged by Banks: Section 85 of the National Bank Act (“NBA”), 12 U.S.C. §

FDIC 78

FDIC National South Dakota Lending 78

Jeff For Banks

JUNE 20, 2017

The banking system is stable, which is critical to national and state economies. According to the FDIC , disparate impact occurs when a policy or practice applied equally to all applicants has a disproportionate adverse impact on applicants in a protected group. I got news for our lawmakers and regulators. Also critical.

Data 60

Data FDIC Regulation Washington 60

CFPB Monitor

JULY 22, 2020

Less than two months after issuing its final “ Madden fix” rule , the OCC has now issued a proposed rule to address when a national bank or federal savings association should be considered the “true lender” in the context of a third party relationship. Presumably, we will soon see a proposed “true lender” rule from the FDIC.

National 78

National Lending Exercises FDIC 78

PYMNTS

DECEMBER 14, 2018

Among those agencies, alphabetically speaking: the Office of the Comptroller of the Currency (OCC), the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation (FDIC), the Financial Crimes Enforcement Network (FinCEN) and the National Credit Union Administration.

Compliance 148

Compliance Innovation FDIC Examples 148

CFPB Monitor

MAY 6, 2019

In doing so, the court found that the term “business of banking” as used in the National Bank Act (NBA) “unambiguously requires receiving deposits as an aspect of the business.”. 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.

Fintech 68

Fintech New York National Regulation 68

CFPB Monitor

NOVEMBER 24, 2020

The OCC observes that, in denying services, banks “are often reacting to pressure from advocates from across the political spectrum whose policy objectives are served when banks deny certain categories of customers access to financial services.” Comments on the proposal are due by January 4, 2021.

Operations 78

Operations Analysis Industry Policies 78

CFPB Monitor

JULY 1, 2020

The agencies are the Comptroller of the Currency, Farm Credit Administration, FDIC, Federal Reserve Board, and National Credit Union Administration. The agencies’ expectations regarding a lender’s obligation when there is a discrepancy between the flood determination form and the flood insurance policy. Detached Structures.

Policies 60

Policies Security FDIC National 60

Independent Banker

SEPTEMBER 22, 2015

Both of these laws pointedly changed the National Flood Insurance Program requirements over which of the banking agencies have jurisdiction. for the entire term of the loan and did not have a policy of uniformly and consistently escrowing. Model language has been provided in Appendix A of the regulation. Escrow obligations.

Regulation 70

Regulation Policies Community Bank Taxes 70

American Banker

MAY 24, 2016

In guidance on banks' resolution plans, regulators effectively have made important policy decisions about liquidity transformation that were not subject to notice and comment.

Policies 39

Policies Regulation FDIC Regional 39

Independent Banker

DECEMBER 13, 2015

The bank’s assistant vice president for cybersecurity and data security policy, he says the tool “gives you another window to look at what you have, to qualify and quantify your risk.”. These agencies had input: the Federal Reserve, the Office of the Comptroller of the Currency, FDIC and the National Credit Union Administration.

Tools 70

Tools Community Community Bank Security 70

Independent Banker

NOVEMBER 24, 2015

The bank’s assistant vice president for cybersecurity and data security policy, he says the tool “gives you another window to look at what you have, to qualify and quantify your risk.”. These agencies had input: the Federal Reserve, the Office of the Comptroller of the Currency, FDIC and the National Credit Union Administration.

Tools 70

Tools Community Community Bank Security 70

American Banker

AUGUST 29, 2016

Kansas City Federal Reserve Bank President Esther George is best known nationally as a critic of the Fed’s monetary policy, but in a wide-ranging interview she talks about Dodd-Frank, bank capitalization and the challenges facing community banking, in addition to interest rates.

Kansas City 31

Kansas City Kansas Community Bank Policies 31

CFPB Monitor

JULY 12, 2022

However, regulators themselves have been criticized for encouraging de-risking by driving highly risk-adverse decisions by FIs, who are unwilling to take the chance and assume the compliance costs of doing business with specific customers who may in fact be “legitimate,” but whose risk profile is deemed to be high due to their group affiliation.

Regulation 78

Regulation ATM Operations Policies 78

CFPB Monitor

MAY 22, 2020

The Federal Reserve, OCC, FDIC, and NCUA have issued “ Interagency Lending Principles for Offering Responsible Small-Dollar Loans.” Underwriting loan products based on prudent policies and practices governing amounts borrowed, borrowing frequency, and repayment terms.

FDIC 78

FDIC Policies Lending Guidelines 78

CFPB Monitor

MARCH 10, 2022

The Order sets out the following national objectives with respect to digital assets: consumer and investor protection; protection of financial stability and mitigation of systemic risk; mitigation of illicit finance and national security risks; reinforcement of U.S.

FDIC 148

FDIC National cryptocurrency Leadership 148

CFPB Monitor

NOVEMBER 19, 2018

Thirteen Republican Senators have sent a letter to FDIC Chairman Jelena McWilliams urging the FDIC to take action to ensure that lawful businesses are no longer at risk of adverse financial consequences as a result of “Operation Choke Point, and its associated culture and Choke Point-like regulatory actions.”.

FDIC 68

FDIC Operations Policies Regulation 68

Abrigo

NOVEMBER 22, 2021

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).

Compliance 195

Compliance Lending Risk Management Regulation 195

Independent Banker

MARCH 15, 2015

Policy Development. Housing Policy Task Force, member. Regulation Review Committee, vice chairman. FDIC Advisory Committee on Community Banking, member. National Management Association/Grand Lake chapter, treasurer and president. Both the regulators and Congress respect us for what we stand for,” he observes. “So

Ohio 70

Ohio Community Bank Community Lending 70

CFPB Monitor

MAY 7, 2020

The Bureau states that “neither ECOA nor Regulation B mandate the use of any particular list of reasons. The Bureau encourages entities to consider using the Bureau’s new innovation policies (e.g. No-Action Letter Policy) to address potential compliance issues. Student loan origination. Debt collection and model use.

Lending 78

Lending Report FDIC Policies 78

Independent Banker

JULY 29, 2016

Around the Table—Wisconsin community bankers work with legislative staff members on Capitol Hill during ICBA’s Washington Policy Summit. Washington Policy Summit. a Senate Finance Committee member, in his Capitol Hill office during ICBA’s Wasington Policy Summit. FDIC Assessment Rules. By Courtney Schoenborn.

Community Bank 70

Community Bank Community Washington FDIC 70

CFPB Monitor

NOVEMBER 22, 2022

In particular, the report’s recommendations deserve attention because they are likely to influence future actions by the federal banking regulators and the CFPB. (The The report is also worthwhile reading for its discussion of the role of fintechs and other non-banks in providing consumer financial services and how that role has evolved.).

Fintech 78

Fintech Report Data Lending 78

CFPB Monitor

JUNE 15, 2021

In June 2020, the CFPB proposed amendments to Regulation Z to address the discontinuation of the London Inter-Bank Offered Rate (LIBOR) that is currently used by many creditors as the index for calculating the interest rate on credit cards and other variable-rate consumer credit products. Mortgage Servicing COVID-19 Relief.

Regulation 78

Regulation FDIC Lending Data 78

PYMNTS

SEPTEMBER 25, 2017

In truth, SoFi’s odds were probably never incredibly strong – the FDIC has turned down this type of application multiple times in the past. “So, The FDIC won’t act in a vacuum,” an unnamed source told Reuters. For most regulators, management is the single most important issue.”. Now, they become almost impossible,” Levitt noted.

FDIC 108

FDIC Data Policies Report 108

CFPB Monitor

JUNE 18, 2020

In remarks made during a recent online event held by the Online Lending Policy Institute, Acting Comptroller of the Currency Brian Brooks indicated that the OCC will soon be issuing a “true lender” proposed rule to supplement its recently-released final rule intended to remove the legal uncertainty created by the Second Circuit’s Madden decision.

FDIC 78

FDIC Fintech Policies Online 78