Susan Costonis, C.R.C.M. Compliance Training & Consulting for Financial Institutions

Size: px
Start display at page:

Download "Susan Costonis, C.R.C.M. Compliance Training & Consulting for Financial Institutions"

Transcription

1 The Directors Education Series Fair Lending Training for the Board of Directors Part I Presented by: Susan Costonis, C.R.C.M. Compliance Training & Consulting for Financial Institutions YOUR PRESENTER Susan Costonis is a compliance consultant and trainer. She has worked for large and small institutions in her 36 year career and has been a Certified Regulatory Compliance Manager since Susan has written numerous training manuals and successfully managed compliance programs and exams for institutions that ranged from a community bank to large multi state bank holding companies. She completed the ABA Graduate Compliance School, and the Graduate Banking School of the University of Colorado. She regularly presents to financial institution audiences in several states and translates complex regulations into simple concepts by using humor and real life examples. 2 1

2 The Director s Role Directors play an important role in the success of every financial institution by providing oversight and directing risk management. A recent ABA survey found that Fair Lending was the number one compliance concern given the more volatile regulatory environment that followed the mortgage meltdown. Fair Lending concerns have been heightened by the creation of the CFPB (Consumer Financial Protection Bureau) and expanded enforcement actions. This two part series will address key issues since Fair Lending violations can impede growth plans, impact profitability, and potentially damage the bank s reputation. 3 The Basics: Marketing, Underwriting, & Risk Management What do the regulators expect that the board understands about Fair Lending? What are the seven essential elements that will provide a strong foundation for an effective Fair Lending program? What are the risk factors for Fair Lending in underwriting? What do recent enforcement actions say about violations of Fair Lending laws during loan approval? 4 2

3 Measures for Compliance Directors are responsible for providing their Financial Institutions with a compliance management program that includes preventive, detective and corrective measures to insure compliance with banking laws and regulations. Preventive measures are those that help prevent violations from occurring, which can include: policies, procedures, internal controls, and training. 5 What is a Compliance Management System? An effective compliance management system has three interdependent elements: Board and management oversight Compliance program Compliance audit 6 3

4 A Sound Compliance Program has: Policies and procedures Training Monitoring Consumer complaint response 7 Board of Directors & Management Oversight Demonstrating clear and unequivocal expectations about compliance; Adopting clear policy statements; Appointing a compliance officer with authority and accountability; Allocating resources to compliance functions commensurate with the level and complexity of the institution's operations; Conducting periodic compliance audits; and Providing for recurrent reports by the compliance officer to the board. 4

5 Seven Essential Elements for Fair Lending 1. Understand the types of Discrimination 2. Understand the prohibited basis groups from the ECOA and Fair Housing Act 3. Understand the types of Fair Lending Risk Compliance Program, Overt Discrimination, Disparate treatment in Underwriting, Disparate treatment in Pricing, Disparate treatment in Steering, discriminatory potential in Redlining, Disparate treatment in Marketing 9 Seven Essential Elements for Fair Lending 4. Understand the need for consistency in consumer access to credit and oversight for Unfair, Deceptive, or Abusive Practices 5. Understand the expectations for employee discretion Balance Growth, Profits, and Fair Lending; Monitoring Exceptions 6. Training informs employees of policies, procedures & commitment to Fair Lending 7. Risk review process that includes analysis of potential discrimination on a prohibited basis compared to control groups 10 5

6 Exam Focus by Regulator Web Address https://www.fdic.gov/ Regulator Consumer Financial Protection Bureau FDIC (Federal Deposit Insurance Corporation) OCC (Office of the Comptroller of the Currency) Federal Reserve 11 CFPB Mission Write rules, supervise companies, and enforce federal consumer financial protection laws Restrict unfair, deceptive, or abusive acts or practices Take consumer complaints Promote financial education Research consumer behavior Monitor financial markets for new risks to consumers Enforce laws that outlaw discrimination and other unfair treatment in consumer finance 12 6

7 Fair Lending for Board Members, Management, & Employees Boards, management & employees should understand fair lending requirements. Training should include: Prohibited bases groups under ECOA and the FHA Types of discrimination disparate treatment, disparate impact, overt discrimination Types of fair lending risk, includingunderwriting, pricing, steering, redlining, and servicing/collections Documenting underwriting and pricing decisions for exception loans and denials Consistently applying fair lending policies and procedures Retaining training content and attendance records for review by regulator Significance of recent enforcement actions Monetary penalties and Reputational Risk Creating written loan policies and procedures Following loan policies and procedures when approving exception loans 13 Fair Lending Basics Regulation B, under the Equal Credit Opportunity Act (ECOA) prohibits lenders from discriminating against credit applicants, establishes guidelines for gathering and evaluating credit information, and requires written notification when credit is denied. See the table below for the nine prohibited bases of discrimination for Regulation B. Fair Housing Act The Fair Housing Act, prohibits discrimination by direct providers of housing, such as landlords and real estate companies as well as other entities, such as municipalities, financial institutions and homeowners insurance companies whose discriminatory practices make housing unavailable to persons based on seven prohibited bases. 14 7

8 15 FAIR LENDING TYPES OF DISCRIMINATION General Rule Prohibiting Discrimination (Section ) Reg B prohibits financial institutions from discriminating against an applicant on a prohibited basis regarding any aspect of a credit transaction What would discourage a reasonable person? If a minority applicant is kept waiting for a long time while non minority applicants get immediate attention it would discourage that minority applicant. If an employee says directly, or indirectly, that the applicant probably won t qualify it would be considered discouraging. 16 8

9 Types of Discrimination "Overt evidence of discrimination," when a lender blatantly discriminates on a prohibited basis; Evidence of "disparate treatment," when a lender treats applicants differently based on one of the prohibited factors; and Evidence of "disparate impact," when a lender applies a practice uniformly to all applicants but the practice has a discriminatory effect on a prohibited basis and is not justified by business necessity. 17 Self Assessments for Fair Lending Is there a law that says you MUST conduct a fair lending risk assessment? While the answer is technically NO, even small Financial Institutions are advised to consider conducting a fair lending risk assessment to create a good foundation for internal controls. All these activities should be appropriate for the size and complexity of the Financial Institution. When conducting a risk assessment, at a minimum you should review: Written policies and procedures Board and management reports Training records 18 9

10 Practical Tips for Conducting a Risk Assesment At a minimum you should review: Written policies and procedures Board and management reports Training records Fair Lending Risk Factors Compliance Program 1. Underwriting 2. Pricing 3. Marketing / Advertising 4. Steering 5. Redlining 19 Fair Lending Risk Assessment Summary Chart Low Moderate High Some discretion is allowed in the underwriting and pricing process. A certain amount of subjective criteria is allowed. Loan policy is very strict and little discretion from a pricing sheet or underwriting criteria is allowed. There is no evidence of gaps in geographic or income distribution for lending There have been no fair lending complaints made to the institution or their regulator There are some gaps in geographic or income distribution for lending but they are explained by reasonable exceptions There have been a few fair lending complaints made to the institution or their regulator. The complaints were resolved on a reasonable basis The lending policy allows a high level of discretion and there is no formal loan documentation process for underwriting and pricing. There are significant gaps in geographic or income distribution for lending without reasonable explanation. There have been many fair lending complaints made to the institution and their regulator

11 Mitigating Fair Lending Risks 1. Training This is a HOT BUTTON. 2. Monitoring pricing and policy exceptions 3. Reporting exceptions to the Board and/or Audit committee for review 4. Changing policy if there are excessive continued exceptions 5. Limiting any discretion in loan pricing 6. Requiring documentation of lending decisions 7. Completing a fair lending risk assessment 21 Customer complaints All the regulators have added substantial sections to their websites to help consumers file various types of complaints, including fair lending complaints. Look at your primary regulator s process Develop a complaint policy & procedures Analyze complaints Train your employees Check vendor contracts; They should be required to inform your financial institution of any complaints 22 11

12 CFPB and Consumer Complaints The CFPB submitted a fifth semi annual report to Congress on May 28, Here are a few of the comments about the complaint project that were found in the 178 page report. Highlights CFPB has an Office of Consumer Response, they have received over 332,300 consumer complaints on credit reporting, debt collection, money transfers, bank accounts and services, credit cards, mortgages, vehicle loans, payday loans and student loans as of March 31, In November 2013 the CFPB added debt collection complaints to the range of products Complaint process is covered under Consumer Concerns and explained on pages of the report 23 Complaints by Product 24 12

13 The Four D S at the CFPB KEY TAKE AWAYS Speech, 10/24/14 They are problems we see much too often: deceptive marketing, debt traps, dead end markets, and discrimination Deceptive marketing project Know before you Owe Debt traps payday lending Dead ends 30 million Americans one in seven consumers came out of the financial crisis with one or more debts in collection; credit reporting Discrimination access to credit, complaint database more than 460,000 complaints 25 CFPB and Department of Justice VS. GE Capital June 19, 2014 CFPB Orders GE Capital to Pay $225 Million in Consumer Relief for Deceptive and Discriminatory Credit Card Practices Marketed the product as free of charge Failed to disclose consumers ineligibility Failed to disclose that consumers were making a purchase Marketed products as a limited time offer Discriminatory Credit Practices offers, GE Capital did not extend these offers to any customer who indicated that they preferred to communicate in Spanish or had a mailing address in Puerto Rico, even if the customer met the promotion s qualifications

14 HUD and Maternity Leave Violation of the Fair Housing Act FirstBank Mortgage Partners has been fined $35,000 by the U.S. Department of Housing and Urban Development to settle allegations that the lender violated the Fair Housing Act by denying a mortgage loan to a couple because one applicant was on maternity leave. This instance is at least the third maternity related fine levied by HUD in the last several months. In July, HUD and the Department of Justice settled claims against Bank of America, PNC Mortgage, Cornerstone Mortgage, and MGIC, among other companies, alleging that the companies engaged in maternity discrimination. Earlier in July, mortgage lender Greenlight Financial Services was fined $48,000 to settle allegations that it violated the Fair Housing Act when it denied or delayed mortgage loans to women because they were on maternity leave. 27 HUD and Disability Violation of the Fair Housing Act August 13, 2014 Freedom Mortgage, a national residential mortgage lender based in Mt. Laurel, New Jersey, has been ordered to pay $104,000 by the U.S. Department of Housing and Urban Development to settle claims that the lender discriminated against loan applicants with disabilities. In one case, a loan applicant provided medical documentation of his disability, a Department of Labor Work Capacity Evaluation form, and a benefits statement showing regular disability payments since Nonetheless, Freedom Mortgage allegedly continued to request proof that the income would continue for at least three years. As part of the settlement with HUD, Freedom Mortgage will establish a system to provide relief to the discrimination victims, in the form of payments of $1,000, $2,000, or $5,000 in damages

15 HUD and Redlining Violations October 2, 2014 HUD announced today that it has negotiated a Conciliation Agreement with Illinois based Midland States Bancorp, resolving allegations that the bank avoided doing business in predominantly African American and Hispanic neighborhoods in St. Louis, Missouri and northern Illinois. The settlement with Midland States Bancorp is the result of a housing discrimination complaint that was filed by Metropolitan St. Louis Equal Housing and Opportunity Council (EHOC), a HUD Fair Housing Initiatives Program agency. EHOC s complaint alleged that the bank delineated its service area in a discriminatory manner that excluded areas of high minority concentration, a practice known as redlining. Agreed to originate $8 million in mortgage loans in majority minority neighborhoods over the next three years, and establish a $550,000 Subsidy Fund; originate $3 million in home repair loans in majorityminority census tracts, and establish a $400,000 Subsidy Fund 29 Final Thoughts & Discussion Items Discuss the effectiveness of the bank s current Fair Lending program to detect risks in discriminatory treatment. Does our bank have any particular risks based on new products, vendor relationships, acquisition of other institutions, or expanded retail footprint? How effective is our risk assessment process for Fair Lending? Do we have adequate staff? Has training been effective? 30 15

Fair Lending, UDAAP and CRA: Protecting Your Bank from Allegations of Fair and Responsible Lending Violations

Fair Lending, UDAAP and CRA: Protecting Your Bank from Allegations of Fair and Responsible Lending Violations Fair Lending, UDAAP and CRA: Protecting Your Bank from Allegations of Fair and Responsible Lending Violations Albany, NY April 23, 2015 Legal Counsel to the Financial Services Industry Presented by Warren

More information

Fair Lending Overview. Division of Depositor and Consumer Protection

Fair Lending Overview. Division of Depositor and Consumer Protection Fair Lending Overview Fair Lending Regulations Equal Credit Opportunity Act (ECOA) Prohibits discrimination in any aspect of a consumer or commercial credit transaction Fair Housing Act (FHA) Prohibits

More information

THE ATTORNEY GENERAL S 2006 ANNUAL REPORT TO CONGRESS PURSUANT TO THE EQUAL CREDIT OPPORTUNITY ACT AMENDMENTS OF 1976

THE ATTORNEY GENERAL S 2006 ANNUAL REPORT TO CONGRESS PURSUANT TO THE EQUAL CREDIT OPPORTUNITY ACT AMENDMENTS OF 1976 THE ATTORNEY GENERAL S 2006 ANNUAL REPORT TO CONGRESS PURSUANT TO THE EQUAL CREDIT OPPORTUNITY ACT AMENDMENTS OF 1976 SUBMITTED BY WAN J. KIM ASSISTANT ATTORNEY GENERAL MARCH 13, 2007 This report is submitted

More information

New and Re-emerging Fair Lending Risks. Article by Austin Brown & Loretta Kirkwood October 2014

New and Re-emerging Fair Lending Risks. Article by Austin Brown & Loretta Kirkwood October 2014 New and Re-emerging Fair Lending Risks Article by Austin Brown & Loretta Kirkwood BY AUSTIN BROWN & LORETTA KIRKWOOD Austin Brown Loretta Kirkwood Regulators have been focused recently on several new and

More information

2015 Interagency Fair Lending Hot Topics

2015 Interagency Fair Lending Hot Topics 2015 Interagency Fair Lending Hot Topics Outlook Live Webinar October 15, 2015 Visit us at www.consumercomplianceoutlook.org Visit us at www.consumercomplianceoutlook.org 1 Welcome to Outlook Live Logistics

More information

Fair Lending Report of the Consumer Financial Protection Bureau

Fair Lending Report of the Consumer Financial Protection Bureau Fair Lending Report of the Consumer Financial Protection Bureau April 2015 Message from Richard Cordray Director of the CFPB The Consumer Financial Protection Bureau (the Bureau or CFPB) is the nation

More information

Case: 4:15-cv-01492 Doc. #: 1 Filed: 09/29/15 Page: 1 of 10 PageID #: 1 UNITED STATES DISTRICT COURT EASTERN DISTRICT OF MISSIOURI EASTERN DIVISION

Case: 4:15-cv-01492 Doc. #: 1 Filed: 09/29/15 Page: 1 of 10 PageID #: 1 UNITED STATES DISTRICT COURT EASTERN DISTRICT OF MISSIOURI EASTERN DIVISION Case: 4:15-cv-01492 Doc. #: 1 Filed: 09/29/15 Page: 1 of 10 PageID #: 1 UNITED STATES DISTRICT COURT EASTERN DISTRICT OF MISSIOURI EASTERN DIVISION UNITED STATES OF AMERICA, ) ) Plaintiff, ) Case No. )

More information

Fair Housing Act. Reference Guide to Regulatory Compliance. 42 USC Ch 45 3601 through 3619

Fair Housing Act. Reference Guide to Regulatory Compliance. 42 USC Ch 45 3601 through 3619 Reference Guide to Regulatory Compliance Fair Housing Act 42 USC Ch 45 3601 through 3619 Topics Coverage Requirements Enforcement Practical Application Self-Study Questions The Fair Housing Act was enacted

More information

Takeaways From GE Capital's $225M Credit Card Settlement

Takeaways From GE Capital's $225M Credit Card Settlement Portfolio Media. Inc. 860 Broadway, 6th Floor New York, NY 10003 www.law360.com Phone: +1 646 783 7100 Fax: +1 646 783 7161 customerservice@law360.com Takeaways From GE Capital's $225M Credit Card Settlement

More information

2013 Interagency Fair Lending Hot Topics

2013 Interagency Fair Lending Hot Topics 2013 Interagency Fair Lending Hot Topics Outlook Live Webinar October 24, 2013 Non-Discrimination Working Group of the Financial Fraud Enforcement Task Force Visit us at www.consumercomplianceoutlook.org

More information

CFPB Examination Procedures

CFPB Examination Procedures Equal Credit Opportunity Act Baseline Review Modules Exam Date: Prepared By: Reviewer: Docket #: Entity Name: The Equal Credit Opportunity Act () Baseline Review Modules will be used by examiners during

More information

Regulatory Practice Letter January 2013 RPL 13-01

Regulatory Practice Letter January 2013 RPL 13-01 Regulatory Practice Letter January 2013 RPL 13-01 Fair Lending CFPB Annual Report and Supervisory Highlights Executive Summary In December 2012, the Bureau of Consumer Financial Protection ( CFPB or Bureau

More information

A CONSUMER GUIDE TO FAIR LENDING

A CONSUMER GUIDE TO FAIR LENDING FAIR HOUSING LEGAL SUPPORT CENTER A CONSUMER GUIDE TO FAIR LENDING AND HOME OWNERSHIP PRESERVATION A CONSUMER GUIDE TO FAIR LENDING AND HOME OWNERSHIP PRESERVATION OVERVIEW This guide explains your right

More information

Hot Topics in Fair Lending

Hot Topics in Fair Lending Hot Topics in Fair Lending Andrea J. Shaw, Counsel, TD Bank James Cohen, Partner, Verrill Dana, LLP 1 April 2012 Fair Lending: Basic to How Banks Offer Mortgages to Public Issue: Whether a lender is improperly

More information

MBA of Central Florida Washington Update. Brian Chappelle Potomac Partners

MBA of Central Florida Washington Update. Brian Chappelle Potomac Partners MBA of Central Florida Washington Update Brian Chappelle Potomac Partners Overview Some things haven t changed Companies that know how to implement & follow rules have benefited Knowledge and customer

More information

High-Risk Areas, Common Compliance Violations, and CMPs: Solutions and Tips. FDIC Compliance Examiner John George April 25, 2013

High-Risk Areas, Common Compliance Violations, and CMPs: Solutions and Tips. FDIC Compliance Examiner John George April 25, 2013 High-Risk Areas, Common Compliance Violations, and CMPs: Solutions and Tips FDIC Compliance Examiner John George April 25, 2013 Overview HMDA Errors and Mitigating Strategies Fair Lending Issues Other

More information

2014 National Update: Service Contracts Ancillary Products

2014 National Update: Service Contracts Ancillary Products 2014 National Update: Service Contracts Ancillary Products Timothy J. Meenan General Counsel to Service Contract Industry Council Motor Vehicle Ancillary Products Association Meenan PA Managing Shareholder

More information

Guide to Fair Mortgage Lending and Home Preservation

Guide to Fair Mortgage Lending and Home Preservation Guide to Fair Mortgage Lending and Home Preservation Fair Housing Legal Support Center & Clinic Guide to Fair Mortgage Lending and Home Preservation What does this guide cover? What is Fair Lending? What

More information

Fair Lending Analysis Made Easy. Presented by: Ian Dunn CEO,

Fair Lending Analysis Made Easy. Presented by: Ian Dunn CEO, Fair Lending Analysis Made Easy Presented by: Ian Dunn CEO, Agenda 1 The Basics 2 Assessing Your Potential Fair Lending Risk Exposure 3 Key Fair Lending Analysis & Reporting The Basics- Fair Lending Laws

More information

What Lead Generators Need to Know About the Consumer Financial Protection Bureau (CFPB)

What Lead Generators Need to Know About the Consumer Financial Protection Bureau (CFPB) What Lead Generators Need to Know About the Consumer Financial Protection Bureau (CFPB) LeadsCon March 18, 2013 Mirage Hotel & Casino, Las Vegas, NV Jonathan L. Pompan Venable LLP 1 Agenda for Today What

More information

Fair Lending Update. 2012 Banker Outreach Program

Fair Lending Update. 2012 Banker Outreach Program Fair Lending Update 2012 Banker Outreach Program Fair Lending Discussion Topics: Fair Lending High Risks Areas Pricing and Underwriting Examination Focus and Procedures How to Conduct a Comparative Analysis

More information

2014 NCUA Fair Lending Examinations. MDDCCUA Training

2014 NCUA Fair Lending Examinations. MDDCCUA Training 2014 NCUA Fair Lending Examinations MDDCCUA Training October 30, 2013 E. Andrew Keeney, Esq. Kaufman & Canoles, P.C. E. Andrew Keeney, Esq. Kaufman & Canoles, P.C. 150 West Main Street, Suite 2100 Norfolk,

More information

RISK MANAGEMENT UPDATE Lessons [To Be] Learned from Recent Enforcement Actions

RISK MANAGEMENT UPDATE Lessons [To Be] Learned from Recent Enforcement Actions RISK MANAGEMENT UPDATE Lessons [To Be] Learned from Recent Enforcement Actions Presented by: Dixie K. Hieb and Robb Schlimgen Davenport, Evans, Hurwitz & Smith, LLP www.dehs.com 2014 Davenport, Evans,

More information

CFPB Consumer Laws and Regulations

CFPB Consumer Laws and Regulations General Principles and Introduction Supervised entities within the scope of CFPB s supervision and enforcement authority include both depository institutions and non-depository consumer financial services

More information

Disparate Impact Considerations for Private Education Loans

Disparate Impact Considerations for Private Education Loans Disparate Impact Considerations for Private Education Loans Arthur J. Rotatori, Esq. McGlinchey Stafford 25550 Chagrin Blvd., Suite 406 Cleveland, Ohio 44122 (216) 378-9932 arotatori@mcglinchey.com Fair

More information

Regulatory Compliance - What You Need to Know. John Zasada Principal CliftonLarsonAllen 218 790 1086 John.zasada@claconnect.com

Regulatory Compliance - What You Need to Know. John Zasada Principal CliftonLarsonAllen 218 790 1086 John.zasada@claconnect.com Regulatory Compliance - What You Need to Know John Zasada Principal CliftonLarsonAllen 218 790 1086 John.zasada@claconnect.com Compliance Risk Defense or move forward It exists for all FIs Identify, rank,

More information

PUBLIC DISCLOSURE COMMUNITY REINVESTMENT ACT PERFORMANCE EVALUATION. October 18, 1996. Harris Bank Elk Grove, N.A. Charter Number: 15916

PUBLIC DISCLOSURE COMMUNITY REINVESTMENT ACT PERFORMANCE EVALUATION. October 18, 1996. Harris Bank Elk Grove, N.A. Charter Number: 15916 Comptroller of the Currency Administrator of National Banks Chicago Northwest Duty Station 85 West Algonquin Road, Suite 340 Arlington Heights, IL 60005 PUBLIC DISCLOSURE COMMUNITY REINVESTMENT ACT PERFORMANCE

More information

Fair Lending and HMDA Compliance

Fair Lending and HMDA Compliance Office of Consumer Protection Consumer Compliance Policy & Outreach Fair Lending and HMDA Compliance February 20, 2015 The information contained in this presentation is for informational purposes only

More information

The Attorney General s 2014 Annual Report to Congress Pursuant to the Equal Credit Opportunity Act Amendments of 1976 Submitted by

The Attorney General s 2014 Annual Report to Congress Pursuant to the Equal Credit Opportunity Act Amendments of 1976 Submitted by The Attorney General s 2014 Annual Report to Congress Pursuant to the Equal Credit Opportunity Act Amendments of 1976 Submitted by Vanita Gupta Acting Assistant Attorney General Civil Rights Division April

More information

CFPB. Nature and Structure of Products

CFPB. Nature and Structure of Products The sections below include (1) factors that specifically increase the risk that unfair, deceptive, abusive acts or practices, discrimination, or other violations of Federal consumer financial law will

More information

Banker s Guide To Risk-Based Fair Lending Examinations

Banker s Guide To Risk-Based Fair Lending Examinations Banker s Guide To Risk-Based Fair Lending Examinations RESERVE BANK OF FEDERAL CHICAGO INCORPORATED 1914 MAY 18, Introduction Banker s Guide To Risk-Based Fair Lending This publication is a guide to the

More information

Vendor Management: Who the CFPB is Watching and Who They Are Expecting You to be Watching

Vendor Management: Who the CFPB is Watching and Who They Are Expecting You to be Watching Vendor Management: Who the CFPB is Watching and Who They Are Expecting You to be Watching John Barnes 713.210.7441 jbarnes@bakerdonelson.com Jessica Hinkie 713.210.7405 jhinkie@bakerdonelson.com Kat Statman

More information

Regulatory Practice Letter April 2013 RPL 13-09

Regulatory Practice Letter April 2013 RPL 13-09 Regulatory Practice Letter April 2013 RPL 13-09 CFPB Nonbank Supervision Larger Participants for Student Loan Servicing Proposed Rule Executive Summary The Bureau of Consumer Financial Protection (CFPB

More information

Title XIV - Mortgage Reform and Anti-Predatory Lending Act. Short title: "Mortgage Reform and Anti-Predatory Lending Act"

Title XIV - Mortgage Reform and Anti-Predatory Lending Act. Short title: Mortgage Reform and Anti-Predatory Lending Act Title XIV - Mortgage Reform and Anti-Predatory Lending Act Short title: "Mortgage Reform and Anti-Predatory Lending Act" Subtitles A, B, C, and E are designated as Enumerated Consumer Law under the Bureau

More information

Unfair or Deceptive Acts or Practices by State-Chartered Banks March 11, 2004

Unfair or Deceptive Acts or Practices by State-Chartered Banks March 11, 2004 Board of Governors of the Federal Reserve System Federal Deposit Insurance Corporation Unfair or Deceptive Acts or Practices by State-Chartered Banks March 11, 2004 Purpose The Board of Governors of the

More information

FREQUENTLY ASKED QUESTIONS ABOUT THE NEW HMDA DATA. General Background

FREQUENTLY ASKED QUESTIONS ABOUT THE NEW HMDA DATA. General Background March 31, 2005 FREQUENTLY ASKED QUESTIONS ABOUT THE NEW HMDA DATA General Background 1. What is the Home Mortgage Disclosure Act (HMDA)? HMDA, enacted by Congress in 1975, requires most mortgage lenders

More information

Published by American Bankers Association in March/April 2012 issue of ABA Bank Compliance magazine

Published by American Bankers Association in March/April 2012 issue of ABA Bank Compliance magazine Are Highly Satisfied Customers Fairly Treated Customers? Yes No Maybe By Paul Lubin, Senior Director, Treliant Risk Advisors Published by American Bankers Association in March/April 2012 issue of ABA Bank

More information

Enforcement and Compliance Fall 2015 Update

Enforcement and Compliance Fall 2015 Update Enforcement and Compliance Fall 2015 Update DEPARTMENT OF JUSTICE ANNOUNCES SETTLEMENT WITH CALIFORNIA BANK March 11, 2015 The Department of Justice has settled civil and criminal charges against CommerceWest

More information

Testimony of ANN F. JAEDICKE. Deputy Comptroller for Compliance Policy. Office of the Comptroller of the Currency. Before the

Testimony of ANN F. JAEDICKE. Deputy Comptroller for Compliance Policy. Office of the Comptroller of the Currency. Before the For Release Upon Delivery 9:00 a.m., June 29, 2009 Testimony of ANN F. JAEDICKE Deputy Comptroller for Compliance Policy Office of the Comptroller of the Currency Before the SPECIAL COMMITTEE ON AGING

More information

Conducting Consumer Compliance Risk Assessments Examiner Insights. Agenda. What is a Compliance Risk Assessment? 8/15/2013

Conducting Consumer Compliance Risk Assessments Examiner Insights. Agenda. What is a Compliance Risk Assessment? 8/15/2013 Conducting Consumer Compliance Risk Assessments Examiner Insights Outlook Live Webinar August 20, 2013 Dorothy Stefanyszyn & Joe Detchemendy Examiners Federal Reserve Bank of St. Louis Visit us at www.consumercomplianceoutlook.org

More information

Mortgage Banking. Solutions in Compliance, Transactions, and Defense. Attorney Advertising

Mortgage Banking. Solutions in Compliance, Transactions, and Defense. Attorney Advertising Mortgage Banking Solutions in Compliance, Transactions, and Defense Attorney Advertising The mortgage banking industry is changing rapidly. We offer broad regulatory experience, formidable skill in litigation,

More information

Break Out Session: Mortgage Loan Servicing and Administration

Break Out Session: Mortgage Loan Servicing and Administration Break Out Session: Mortgage Loan Servicing and Administration 2 Agenda Mortgage Servicing Rules (Real Estate Settlement Procedures Act [RESPA] and Truth in Lending Act [TILA]) Effective Date: Applications

More information

VIRGINIA ASSOCIATION OF COMMUNITY BANKS

VIRGINIA ASSOCIATION OF COMMUNITY BANKS VIRGINIA ASSOCIATION OF COMMUNITY BANKS Spring Internal Audit / Risk Seminar Presented by Lee G. Lester May 26, 2016 Regulatory Hot Topics > De-Risking > Marketplace Lending > Consumer protection initiatives

More information

GLOSSARY OF TERMS. Amortization Repayment of a debt in regular installments of principal and interest, rather than interest only payments

GLOSSARY OF TERMS. Amortization Repayment of a debt in regular installments of principal and interest, rather than interest only payments GLOSSARY OF TERMS Ability to Repay (ATR) The Ability to Repay rule protects consumers from taking on mortgages that exceed their financial means, by mandating the documentation / proof of income and assets.

More information

An Introduction to the Community Reinvestment Act for Tribal Communities. Gloria Reynolds Community Affairs Specialist FDIC August 8 th 2013

An Introduction to the Community Reinvestment Act for Tribal Communities. Gloria Reynolds Community Affairs Specialist FDIC August 8 th 2013 An Introduction to the Community Reinvestment Act for Tribal Communities Gloria Reynolds Community Affairs Specialist FDIC August 8 th 2013 What is the CRA? CRA stands for The Community Reinvestment Act

More information

Contents. NCRC Analysis of Bank Account Complaints by Zip Code Summary of Findings. Summary of Findings... 3. Recommendations... 4

Contents. NCRC Analysis of Bank Account Complaints by Zip Code Summary of Findings. Summary of Findings... 3. Recommendations... 4 NCRC Analysis of Bank Account Complaints by ZIP Code 2013 Josh Silver Archana Pradhan Vice President of Research & Policy National Community Reinvestment Coalition Senior Research Analyst National Community

More information

TRUSTED INTELLIGENCE 1

TRUSTED INTELLIGENCE 1 TRUSTED INTELLIGENCE 1 POINT OF VIEW CFPB Know Before You Owe 2 Background The Consumer Financial Protection Bureau (CFPB) established new disclosure rules that become effective on mortgage applications

More information

IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF NEW YORK

IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF NEW YORK IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF NEW YORK UNITED STATES OF AMERICA, ) ) Plaintiff, ) ) v. ) Civil Action No. ) ERIE INSURANCE COMPANY ) OF NEW YORK; ERIE INSURANCE ) COMPANY;

More information

What to Consider Before Developing, Marketing, and Originating Them

What to Consider Before Developing, Marketing, and Originating Them By Phillip R. Rick Freer Jr., CRCM, and Calvin R. Hagins, CRCM, CRP, AMLP Shutterstock Reverse Mortgages: What to Consider Before Developing, Marketing, and Originating Them 6 MARCH APRIL 2010 ABA Bank

More information

Lender Accountability for Lead Generation

Lender Accountability for Lead Generation Lender Accountability for Lead Generation Tips, Tools and Regs That You Should Know About Presented by: Sarah Hulbert, 1 st Reverse Mortgage USA (Moderator) Bill Trask, Security 1 Lending Jean Noble, Urban

More information

REGULATORY COMPLIANCE SERVICES for Financial Institutions

REGULATORY COMPLIANCE SERVICES for Financial Institutions REGULATORY COMPLIANCE SERVICES for Financial Institutions TRUPOINT PARTNERS Regulatory Compliance Services for Financial Institutions THIS IS SMART COMPLIANCE. TRUPOINT PARTNERS PROVIDES COMPLIANCE SOLUTIONS

More information

CFPB and Lenders. A presentation on the Consumer Financial Protection Bureau and its impact on the lending industry

CFPB and Lenders. A presentation on the Consumer Financial Protection Bureau and its impact on the lending industry CFPB and Lenders A presentation on the Consumer Financial Protection Bureau and its impact on the lending industry What is the Consumer Financial Protection Bureau (CFPB)? Independent agency of the United

More information

June 2006 Report No. 06-011. Challenges and FDIC Efforts Related to Predatory Lending AUDIT REPORT

June 2006 Report No. 06-011. Challenges and FDIC Efforts Related to Predatory Lending AUDIT REPORT June 2006 Report No. 06-011 Challenges and FDIC Efforts Related to Predatory Lending AUDIT REPORT Report No. 06-011 June 2006 Challenges and FDIC Efforts Related to Predatory Lending Results of Audit Background

More information

Board of Directors and Management Oversight

Board of Directors and Management Oversight Board of Directors and Management Oversight Examination Procedures Examiners should request/ review records, discuss issues and questions with senior management. With respect to board and senior management

More information

introduced the following bill; which was referred to the Committee on A BILL

introduced the following bill; which was referred to the Committee on A BILL To preserve competition among mortgage lenders, provide relief from unnecessary regulatory requirements on responsible community mortgage lenders, and for other purposes. introduced the following bill;

More information

FAIR LENDING: WHY MAPS MATTER

FAIR LENDING: WHY MAPS MATTER Headquarters TCA / Thomas Compliance Associates, Inc. 2846 N. Mildred Avenue, Suite 150, Chicago, Illinois 60657-5052 800-934- REGS 800-934- 7347 www.tcaregs.com A TCA MANAGEMENT PAPER FAIR LENDING: WHY

More information

Consumer Protection and Regulatory Changes in the Dodd-Frank Bill

Consumer Protection and Regulatory Changes in the Dodd-Frank Bill 31 August 2010 Part II of A NERA Insights Series Consumer Protection and Regulatory Changes in the Dodd-Frank Bill By Dr. Ethan Cohen-Cole Summary On 21 July 2010, President Obama signed into law the Dodd-Frank

More information

Quarterly Conversations: Live from First State Bank and Trust Caruthersville, Missouri. August 19, 2015

Quarterly Conversations: Live from First State Bank and Trust Caruthersville, Missouri. August 19, 2015 Quarterly Conversations: Live from First State Bank and Trust Caruthersville, Missouri August 19, 2015 1 Options to Join the Conversation Webinar and audio Click on the link: https://www.webcaster4.com/webcast/page/584/8667

More information

Importance of the Consumer Financial Protection Bureau

Importance of the Consumer Financial Protection Bureau Importance of the Consumer Financial Protection Bureau The aftermath of the financial crisis affected millions of Americans. The U.S. economy was devastated as companies crumbled, homeowners lost their

More information

The CFPB and Medical Collections: Unknown Territory in the Face of Sweeping Regulatory Change

The CFPB and Medical Collections: Unknown Territory in the Face of Sweeping Regulatory Change The CFPB and Medical Collections: Unknown Territory in the Face of Sweeping Regulatory Change Agenda What is the CFPB? Brief chronology of the CFPB CFPB investigations and examinations; the cost of non-compliance

More information

Financial Services Update June 11, 2013

Financial Services Update June 11, 2013 Financial Services Update June 11, 2013 HIGHLIGHTS Federal Regulatory Developments: CFPB Amends Examination Manual State Regulatory Developments: Texas Proposes Constitutional Amendment Regarding Reverse

More information

IN THE UNITED STATES DISTRICT COURT FOR THE CENTRAL DISTRICT OF CALIFORNIA

IN THE UNITED STATES DISTRICT COURT FOR THE CENTRAL DISTRICT OF CALIFORNIA 1 of 5 7/6/2007 11:19 AM IN THE UNITED STATES DISTRICT COURT FOR THE CENTRAL DISTRICT OF CALIFORNIA UNITED STATES OF AMERICA, Plaintiff, v. LONG BEACH MORTGAGE COMPANY, Defendant. COMPLAINT FOR COMPENSATORY

More information

Dodd Frank Act Consumer Financial Protection Bureau Mortgage Lending

Dodd Frank Act Consumer Financial Protection Bureau Mortgage Lending Dodd Frank Act Consumer Financial Protection Bureau Mortgage Lending A Briefing for the Texas House Investments and Financial Services Committee John C. Fleming Consumer Financial Protection Bureau (CFPB)

More information

Mark W Olson: Home Mortgage Disclosure Act

Mark W Olson: Home Mortgage Disclosure Act Mark W Olson: Home Mortgage Disclosure Act Testimony by Mr Mark W Olson, Member of the Board of Governors of the US Federal Reserve System, before the Subcommittee on Financial Institutions and Consumer

More information

10 Steps to a Successful Regulatory Compliance Program

10 Steps to a Successful Regulatory Compliance Program 10 Steps to a Successful Regulatory Compliance Program John Zasada Principal, Regulatory Compliance Services CliftonLarsonAllen LLP 218.790.1086 John.zasada@cliftonlarsonallen.com 1 1 Introducing John

More information

Consumer Financial Protection Bureau Two Years In and Just Beginning the Baby Steps

Consumer Financial Protection Bureau Two Years In and Just Beginning the Baby Steps Consumer Financial Protection Bureau Two Years In and Just Beginning the Baby Steps By Thomas J. King, Standing Chapter 13 Trustee for the Eastern District of Wisconsin The Consumer Financial Protection

More information

Table of Contents... 1. Chapter 1 Introduction... 5. 1.1 Goals & Objectives... 5 1.2 Required Review... 5 1.3 Applicability...

Table of Contents... 1. Chapter 1 Introduction... 5. 1.1 Goals & Objectives... 5 1.2 Required Review... 5 1.3 Applicability... ... 1 Chapter 1 Introduction... 5 1.1 Goals & Objectives... 5 1.2 Required Review... 5 1.3 Applicability... 5 Chapter 2 Company Culture... 6 Chapter 3 Risk Management Governance... 7 3.1 Board of Directors...

More information

Supervisory Highlights. Summer 2013

Supervisory Highlights. Summer 2013 Supervisory Highlights Summer 2013 Table of Contents 1. Introduction... 3 2. Supervisory Observations... 5 2.1 Compliance Management Systems... 5 2.2 Mortgage Servicing... 11 2.3 Fair Lending Provision

More information

CFPB COMPLIANCE: Interaction Between Compliance Assessments and Systems Issues

CFPB COMPLIANCE: Interaction Between Compliance Assessments and Systems Issues CFPB COMPLIANCE: Interaction Between Compliance Assessments and Systems Issues Presented by: Stefanie H. Jackman Consumer Financial Services Group 678.420.9490 jackmans@ballardspahr.com Trevor Salter Consumer

More information

211 CMR: DIVISION OF INSURANCE 211 CMR 142.00: INSURANCE SALES BY BANKS AND CREDIT UNIONS

211 CMR: DIVISION OF INSURANCE 211 CMR 142.00: INSURANCE SALES BY BANKS AND CREDIT UNIONS 211 CMR 142.00: INSURANCE SALES BY BANKS AND CREDIT UNIONS Section 142.01: Scope and Purpose 142.02: Applicability 142.03: Definitions 142.04: Licensing 142.05: Consumer Protection Terms and Conditions

More information

Income Verification Asset Verification Property Documentation

Income Verification Asset Verification Property Documentation Independence Title Are you buying or selling a home after October 3, 2015? Nationwide the mortgage lending industry (creditors) will face a big change beginning October 3rd of this year. Here are the 3

More information

A Field Guide to Taming It has been nearly 10 years since the unfair,

A Field Guide to Taming It has been nearly 10 years since the unfair, By Meg Sczyrba, CRCM, and Phillip R. Rick Freer, Jr., CRCM A Field Guide to Taming It has been nearly 10 years since the unfair, deceptive or abusive acts or practices (UDAAP) beast was first hatched and

More information

Overview of Mortgage Lending

Overview of Mortgage Lending Chapter 1 Overview of Mortgage Lending 1 Chapter Objectives Identify historical events affecting today s mortgage industry. Contrast the primary mortgage market and secondary mortgage market. Identify

More information

CFSA Compliance School, Part II: Implementing an Effective Compliance Management System

CFSA Compliance School, Part II: Implementing an Effective Compliance Management System CFSA Compliance School, Part II: Implementing an Effective Compliance Management System Michelle Hemerley Managing Director FIS Enterprise Governance, Risk & Compliance (EGRC) SoluBon February 2014 Overview

More information

Office of Financial Regulation. Alisa Goldberg Chief, Bureau of Registration Division of Securities

Office of Financial Regulation. Alisa Goldberg Chief, Bureau of Registration Division of Securities Office of Financial Regulation Alisa Goldberg Chief, Bureau of Registration Division of Securities 1 History The Office of Financial Regulation (OFR) was created in 203 by section 20.121(3), Florida Statutes,

More information

SUMMARY OF THE CFPB NOTICE

SUMMARY OF THE CFPB NOTICE COMMENTS OF THE TAX PROBLEM RESOLUTION SERVICES COALITION TO THE BUREAU OF CONSUMER FINANCIAL PROTECTION IN CONSIDERATION OF DOCKET NUMBER CFPB-HQ-2011-2 FOR DEFINING LARGER PARTICIPANTS IN CERTAIN CONSUMER

More information

FREQUENTLY ASKED QUESTIONS ABOUT THE NEW HMDA DATA. General Background

FREQUENTLY ASKED QUESTIONS ABOUT THE NEW HMDA DATA. General Background April 3, 2006 FREQUENTLY ASKED QUESTIONS ABOUT THE NEW HMDA DATA General Background 1. What is the Home Mortgage Disclosure Act (HMDA)? HMDA, enacted by Congress in 1975, requires most mortgage lenders

More information

Regulatory Intelligence Briefing A New Era of Fair Lending

Regulatory Intelligence Briefing A New Era of Fair Lending Regulatory Intelligence Briefing A New Era of Fair Lending August 26, 2015 August 12, 2015 CENTER OF REGULATORY INTELLIGENCE www.fisglobal.com Table of Contents A. Editorial Note from the Managing Director,

More information

2014 Financial Services Industry Compliance Benchmark Study

2014 Financial Services Industry Compliance Benchmark Study 2014 Financial Services Industry Compliance Benchmark Study Presented By: and Executive Summary Beginning in early December 2013, SAI Global Compliance conducted a survey among compliance professionals

More information

Evolving Legal and Regulatory Landscape for Lead Generation

Evolving Legal and Regulatory Landscape for Lead Generation Evolving Legal and Regulatory Landscape for Lead Generation LeadsCon 2012 February 27, 2012 The Mirage Resort & Casino, Las Vegas, NV Jonathan L. Pompan, Esq. Venable LLP, Washington, DC 1 IMPORTANT INFORMATION

More information

Client Update CFPB Issues Final Auto Finance Larger Participant Rule and New Auto Finance Examination Procedures

Client Update CFPB Issues Final Auto Finance Larger Participant Rule and New Auto Finance Examination Procedures 1 Client Update CFPB Issues Final Auto Finance Larger Participant Rule and New Auto Finance Examination Procedures NEW YORK Matthew L. Biben mlbiben@debevoise.com Courtney M. Dankworth cmdankworth@debevoise.com

More information

2102 Illinois Governor's Conference on Affordable Housing Foreclosure Prevention Programs April 16, 2012

2102 Illinois Governor's Conference on Affordable Housing Foreclosure Prevention Programs April 16, 2012 2102 Illinois Governor's Conference on Affordable Housing Foreclosure Prevention Programs April 16, 2012 The 18 month Robo Signing Settlement was announced on February 8 and finalized on April 5, 2012

More information

Regulatory Practice Letter November 2012 RPL 12-20

Regulatory Practice Letter November 2012 RPL 12-20 Regulatory Practice Letter November 2012 RPL 12-20 Private Student Lending - CFPB Reports Executive Summary The Bureau of Consumer Financial Protection ( CFBP or Bureau ) recently released two reports

More information

MORTGAGE LOAN PREQUALIFICATIONS:

MORTGAGE LOAN PREQUALIFICATIONS: MORTGAGE LOAN PREQUALIFICATIONS: APPLICATIONS OR NOT A GUIDE FOR COMPLYING WITH REGULATIONS B AND C Federal Deposit Insurance Corporation Division of Compliance & Consumer Affairs Federal Deposit Insurance

More information

Case 1:14-cv-01028-RMC Document 65-8 Filed 09/30/14 Page 1 of 10 EXHIBIT G

Case 1:14-cv-01028-RMC Document 65-8 Filed 09/30/14 Page 1 of 10 EXHIBIT G Case 1:14-cv-01028-RMC Document 65-8 Filed 09/30/14 Page 1 of 10 EXHIBIT G Case 1:14-cv-01028-RMC Document 65-8 Filed 09/30/14 Page 2 of 10 STATE RELEASE I. Covered Conduct For purposes of this Release,

More information

TRID Survival Guide: Consumer Edition

TRID Survival Guide: Consumer Edition TRID Survival Guide: Consumer Edition What you need to know about the TILA-RESPA Integrated Closing Disclosures. NFM Lending NMLS # 2893 Toll-Free: 1-888-233-0092 www.nfmlending.com Introduction NFM Lending

More information

REGULATORY ALERT NATIONAL CREDIT UNION ADMINISTRATION 1775 DUKE STREET, ALEXANDRIA, VA 22314. DATE: June 5, 1997 NO.: 97-RA-9. TO: All Credit Unions

REGULATORY ALERT NATIONAL CREDIT UNION ADMINISTRATION 1775 DUKE STREET, ALEXANDRIA, VA 22314. DATE: June 5, 1997 NO.: 97-RA-9. TO: All Credit Unions REGULATORY ALERT NATIONAL CREDIT UNION ADMINISTRATION 1775 DUKE STREET, ALEXANDRIA, VA 22314 DATE: June 5, 1997 NO.: 97-RA-9 TO: All Credit Unions Compliance Officer or Chief Executive Officer SUBJECT:

More information

Regulatory Practice Letter December 2012 RPL 12-24

Regulatory Practice Letter December 2012 RPL 12-24 Regulatory Practice Letter December 2012 RPL 12-24 CFPB Nonbank Supervision - Larger Participants for Debt Collection and Credit Reporting Final Rules Executive Summary In February 2012, the Bureau of

More information

INTERAGENCY FAIR LENDING EXAMINATION PROCEDURES

INTERAGENCY FAIR LENDING EXAMINATION PROCEDURES Office of the Comptroller of the Currency Federal Deposit Insurance Corporation Federal Reserve Board Office of Thrift Supervision National Credit Union Administration INTERAGENCY FAIR LENDING EXAMINATION

More information

Managing specialty finance compliance requirements with a compliance management system

Managing specialty finance compliance requirements with a compliance management system Managing specialty finance compliance requirements with a compliance management system Prepared by: Andrew Amrine, Supervisor, RSM US LLP andrew.amrine@rsmus.com, +1 253 382 2239 September 2013 For over

More information

Characteristics of Home Mortgage Lending to Racial or Ethnic Groups in Iowa

Characteristics of Home Mortgage Lending to Racial or Ethnic Groups in Iowa Characteristics of Home Mortgage Lending to Racial or Ethnic Groups in Iowa Liesl Eathington Dave Swenson Regional Capacity Analysis Program ReCAP Department of Economics, Iowa State University September

More information

HOW FINANCIAL INSTITUTIONS ARE USING MYSTERY SHOPPING TO HELP MITIGATE REGULATORY COMPLIANCE ISSUES WHILE IMPROVING THE CUSTOMER EXPERIENCE

HOW FINANCIAL INSTITUTIONS ARE USING MYSTERY SHOPPING TO HELP MITIGATE REGULATORY COMPLIANCE ISSUES WHILE IMPROVING THE CUSTOMER EXPERIENCE HOW FINANCIAL INSTITUTIONS ARE USING MYSTERY SHOPPING TO HELP MITIGATE REGULATORY COMPLIANCE ISSUES WHILE IMPROVING THE CUSTOMER EXPERIENCE by Michael Matza, Senior Strategic Consulting Director, Maritz

More information

Indirect Auto Lending and Compliance with the Equal Credit Opportunity Act

Indirect Auto Lending and Compliance with the Equal Credit Opportunity Act CFPB Bulletin 2013-02 Date: March 21, 2013 Subject: Indirect Auto Lending and Compliance with the Equal Credit Opportunity Act This bulletin provides guidance about compliance with the fair lending requirements

More information

Fair Lending: Learn the Facts

Fair Lending: Learn the Facts Fair Lending: Learn the Facts Now, I say to you today my friends, even though we face the difficulties of today and tomorrow, I still have a dream. It is a dream deeply rooted in the American dream. I

More information

CFPB Examination Procedures

CFPB Examination Procedures Commonly Known as Payday Lending These examination procedures apply to the short-term, small-dollar credit market, commonly known as payday lending. The procedures are comprised of modules covering a payday

More information

UNFAIR, DECEPTIVE, OR ABUSIVE ACTS OR PRACTICES (UDAAP)

UNFAIR, DECEPTIVE, OR ABUSIVE ACTS OR PRACTICES (UDAAP) UNFAIR, DECEPTIVE, OR ABUSIVE ACTS OR PRACTICES (UDAAP) EXAMINATION PROCEDURES Examination Objectives To assess the quality of the credit union s compliance risk management systems, including internal

More information

Regulatory Practice Letter February 2014 RPL 14-05

Regulatory Practice Letter February 2014 RPL 14-05 Regulatory Practice Letter February 2014 RPL 14-05 CFPB Nonbank Supervision of International Money Transfer Providers Proposed Rule Executive Summary The Consumer Financial Protection Bureau (CFPB or Bureau)

More information

FEDERAL HOUSING FINANCE AGENCY OFFICE OF INSPECTOR GENERAL

FEDERAL HOUSING FINANCE AGENCY OFFICE OF INSPECTOR GENERAL FEDERAL HOUSING FINANCE AGENCY OFFICE OF INSPECTOR GENERAL FHFA Should Develop and Implement a Risk-Based Plan to Monitor the Enterprises Oversight of Their Counterparties Compliance with Contractual Requirements

More information

Compliance Management Systems A Blueprint for Success

Compliance Management Systems A Blueprint for Success Compliance Management Systems A Blueprint for Success Date or subtitle May 13, 2015 1 Tim Tedrick, CRCM, CRP Partner 815.626.1277 ttedrick@wipfli.com 2 Page 1 Regulatory FDIC https://www.fdic.gov/regulations/compliance/manual/p

More information

Unfair, Deceptive or Abusive Acts or Practices Act (UDAAP)..It May Not Be What You Think

Unfair, Deceptive or Abusive Acts or Practices Act (UDAAP)..It May Not Be What You Think Unfair, Deceptive or Abusive Acts or Practices Act (UDAAP)..It May Not Be What You Think November 15, 2012 Mary Thorson VP, Chartwell Compliance/ICBA CRM I. UDAAP Overview Background II. UDAAP An emerging

More information