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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,

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

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

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

  In the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank) of 2010, Congress directed the Consumer Financial Protection Bureau (CFPB) to adopt regulations that will govern data collection for small business and agricultural lending. Section 1071 of Dodd-Frank amended the Equal Credit Opportunity Act (ECOA, Reg. B) to require financial institutions to collect and submit specific data to the CFPB. Congress enacted section 1071 for the purpose of: Facilitating enforcement of fair lending laws.