Archive

COMPUTER SECURITY INCIDENTS – WHO TO CONTACT?

On November 17, 2021, the Office of the Comptroller of the Currency (OCC), Treasury; the Board of Governors of the Federal Reserve System (Board); and the Federal Deposit Insurance Corporation (FDIC) released a final rule that requires a banking organization to notify its primary federal regulator of any “computer-security incident” that rises to the level of a “notification incident,” as soon as possible and no later than 36 hours after the banking organization determines that a notification […]

PLAN FOR PROPERTY APPRAISAL AND VALUATION EQUITY

Over the past few years, stories have circulated about properties being appraised for less than typical market value. When the property is reappraised, after the homeowner removes all evidence of his or her blackness, the property appraises for market value. On October 14, 2020, it was reported that an unnamed individual (Complainant) filed a complaint against JPMorgan Chase Bank, N.A. with the United States Department of Housing and Urban Development (“Department”), alleging Complainant was injured […]

OCC IMPOSES CMP FOR FUNDS AVAILABILITY VIOLATION

On February 10, 2022, in a most unusual case, the Office of the Comptroller of the Currency (OCC) issued a Consent Order for the payment of a $3,000 civil money penalty to Craig Meader, the president and a board member of First National Bank of Kansas, Burlington, Kansas. The OCC found, and Meader neither admits nor denies, that, during the period from August to September 2020, Meader directed employees to implement extended holds on ACH deposits […]

CFPB EXPANDS DISCRIMINATION PROTECTION TO DEPOSIT ACCOUNTS

On March 16, 2022, the Consumer Financial Protection Bureau (CFPB) announced that is using Unfair, Deceptive and Abusive Acts and Practices (UDAAP) rules to prevent discrimination in all consumer finance markets including credit, servicing, collections, consumer reporting, payments, remittances, and deposits. Examiners will require supervised companies to show their processes for assessing risks and discriminatory outcomes, including documentation of customer demographics and the impact of products and fees on different demographic groups. The CFPB will […]