On August 8, 2022, the Federal Deposit Insurance Corporation (FDIC) published a technical correction to two regulations in the Federal Register. The changes were precipitated by the consolidation of the former Consumer Response Center and the Deposit Insurance Section. The resulting entity has been renamed the National Center for Consumer and Depositor Assistance (NCDA). Both the Fair Housing Rule and the Consumer Protection in Sales of Insurance Rule are impacted by the change. FDIC-regulated institutions […]
Month: September 2022
Three Common Adverse Action Pitfalls
Adverse action continues to be one of the most challenging areas for Compliance Officers to ensure compliance. Trying to provide timely decisions to comply with regulatory requirements, making sure the accurate reasons are being provided to applicants on notices or for verbal notification, can be a cumbersome and often a frustrating process. Jack Holzknecht, Founder and Senior Consultant at Compliance Resource, has been training and providing guidance through his blogs, most recently on May 31, […]
Regulatory Bulletin: FDIC Re-Presentment
On August 3, 2022, our very own Kimberly Boatwright brought to your attention the increasing risk of overdraft programs to financial institutions. Discussing the New York State Department of Financial Services (DFS) and their stance on overdraft fees. In that Blog she discussed the DFS position on: Overdraft Fees Relating to Authorize Positive, Settle Negative (“APSN”) Transactions Double Fees Arising from Futile Overdraft Protection Transfers Double Fees Arising from Futile Overdraft Protection Transfers It was […]
REGULATION O – RECENT ENFORCEMENT ACTION
Last month, the Federal Reserve Board (FRB) announced a $9,524,000 fine to be imposed on EagleBank, of Bethesda, Maryland for violations of Regulation O. The bank improperly extended credit to entities owned or controlled by its then-CEO and Chairman, Ronald D. Paul. The FRB: Found that EagleBank had deficient internal controls over insider lending practices between 2015 and 2018: Which allowed the bank to extend credit totaling $99 million to entities that Paul owned or controlled, including certain […]
FFIEC RELEASES CENSUS FLAT FILES AND MEDIAN FAMILY INCOME REPORT
Recently, the Federal Financial Institutions Examination Council (FFIEC) releases the FFIEC Census Flat Files and the Median Family Income Report. The FFIEC Census Flat Files are a convenient method of accessing and analyzing the FFIEC census data that are used to create the HMDA and CRA Aggregate and Disclosure Reports. They contain over 1,000 fields of census data and are updated annually to reflect changes to MSA/MD boundaries announced by the Office of Management and […]