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On April 2, 12019 the FDIC published FIL-19-2019, which shares observations about gaps in financial institutions’ contracts with technology service providers that may require financial institutions to take additional steps to manage their own business continuity and incident response. The FIL reminded agency-supervised financial institutions that: Their boards of directors and senior management are responsible for managing risks related to relationships with technology service providers. Effective contracts are an important risk management tool for overseeing technology

On March 29, the CFPB announced that the HMDA Modified Loan Application Register (LAR) data have been published for approximately 5,400 financial institutions. This is the first year in which additional data reported by certain institutions under the 2015 HMDA rule are available. The Modified LARs contain loan level information for 2018 on individual HMDA filers, modified to protect privacy. A copy of the CFPB’s press release is available here. The 2018 HMDA Modified LARs are

The OCC, Federal Reserve and FDIC have published a final rule delaying the effective date of their rule to address changes in credit loss accounting under U.S. generally accepted accounting principles, including banking organizations’ implementation of the current expected credit losses methodology (CECL). The final rule had an effective date of April 1, 2019, and provides that banking organizations may early adopt the final rule prior to that date. The agencies have determined that a delay

On March 29, 2019 the Department of Housing and Urban Development announced that it is charging Facebook with violating the Fair Housing Act by encouraging, enabling, and causing housing discrimination through the company’s advertising platform. HUD alleges that Facebook unlawfully discriminates based on race, color, national origin, religion, familial status, sex, and disability by restricting who can view housing-related ads on Facebook’s platforms and across the internet. Further, HUD claims Facebook mines extensive data about

The Federal Financial Institutions Examination Council (FFIEC) has released the 2019 edition of the publication, A Guide to HMDA Reporting – Getting it Right (aka the HMDA bible). The 2019 version includes amendments made to HMDA by the Economic Growth, Regulatory Relief, and Consumer Protection Act and the 2018 HMDA interpretive and procedural rule issued by the Consumer Financial Protection Bureau. A copy of the Guide is available at:  https://www.ffiec.gov/hmda/pdf/2019guide.pdf.