On May 30th the President signed HR 5740, extending the NFIP’s authority for an additional 60 days. The law enables FEMA to enter into flood insurance contracts through July 31, 2012. For the past several years Congress has played this funding game. The flood laws need some serious attention. Congress cannot agree on the steps needed to improve the program. So rather than approve long-term funding for the insurance program a series of short-term funding […]
Category: Lending Compliance
ABA ANNUAL COMPLIANCE CONFERENCE
The week of June 10th I will be wandering the halls of the ABA’s Annual Compliance Conference in Orlando. If you plan to be there, please look me up. I would like to put some faces with the names of those who follow my blog. If you can’t be there, check this blog regularly. I plan to post articles regarding anything of interest that I hear or see during the week. Jack
CFPB DELAYS ABILITY TO REPAY RULE
On May 31st the Consumer Financial Protection Bureau (CFPB) announced that it is seeking additional public comment on new data and information that it has received in a rulemaking to require lenders to revise Regulation Z to assess consumers’ ability to repay mortgage loans before extending them credit. The latest comment period will close on July 9, 2012. The CFPB is a new agency so we need to cut them a little slack. What the […]
COMMUNITY BANK INFERIORITY COMPLEX
In my seminars and webinars around the US I frequently refer to the community bank inferiority complex. Many community banks feel that their compliance programs are not as good as programs at larger banks. My response to these laments is to point out that the primary difference between a community bank compliance program and the compliance program at a larger bank is that the larger banks tend to make larger mistakes. There is a never […]
DISCRIMINATION AND THE LAZY BANKER SYNDROME
In a recent case the FDIC claimed a bank violated ECOA and Regulation B by engaging in a pattern or practice of denying applications for a credit card based on an initial match of applicant names to the Office of Foreign Asset Control’s list of Specially Designated Nationals (“SDNs”) without further verification that the applicants were in fact SDNs, which resulted in a disparate impact upon Hispanic applicants. The bank agreed to pay a civil […]