The Office of the Comptroller of the Currency, the Federal Reserve Board, and the Federal Deposit Insurance Corporation (the Agencies) are proposing to clarify their Interagency Questions and Answers Regarding Community Reinvestment to address several community development issues. The Questions and Answers were first published under the auspices of the Federal Financial Institutions Examination Council (FFIEC) in 1996, and were last revised on March 11, 2010. The Agencies propose to: Revise five questions and answers, […]
Category: FDIC
INTERAGENCY APPRAISAL RULES FOR HIGHER-PRICED MORTGAGE LOANS
On January 16, 2013 the FDIC published an interagency rule to amend Regulation Z, as required by the Dodd-Frank Act. The new rule established appraisal requirements for “higher-priced mortgages.” The other federal financial institution regulatory agencies are expected to join the effort on January 18th. The 305-page final rule is effective on January 18, 2014. The new rule prohibits a creditor from extending credit in the form of a higher-priced mortgage loan to any consumer […]
UDAAP – LIST OF VIOLATIONS
The emphasis on Unfair, Deceptive and Abusive Acts or Practices (UDAAP) is increasing. Violations are being cited with increasing frequency. The civil monetary penalties being imposed are substantial. While all of the federal regulatory agencies focus on the issue, the most intense focus seems to come from the Federal Deposit Insurance Corporation (FDIC). While all of the FDIC’s regions appear to be focusing on the issue, the most intense focus appears to be coming from […]
DECEPTIVE MARKETING
We have seen a recent string of enforcement actions from the Consumer Financial Protection Bureau involving deceptive marketing practices. There are lessons for all banks to learn from these actions. What the Actions Had in Common The action was taken by the CFPB in coordination with another federal regulator (FDIC in one and OCC in the other). The action involved huge financial institutions. The action resulted in huge penalties. The actions involved deceptive acts in […]
FDIC – VIOLATION CLASSIFICATION SYSTEM
The Federal Deposit Insurance Corporation (FDIC) recently announced (FIL-41-2012) a revision to the classification system for citing violations identified during compliance examinations. The revisions better communicate the severity of violations and help distinguish more serious violations from those more technical in nature. Violations are assigned to one of three classifications based primarily on the impact on the consumer. The three levels are: Level 3/High Severity – includes violations that may result in restitution to consumers […]