Today, the Office of the Comptroller of the Currency (OCC) announced a $15 million civil money penalty against American Express National Bank (American Express). The penalty is a result of American Express failing to govern and oversee a third-party affiliate and for violations of regulations relating to certain efforts to retain small business customers. This is the first CMP issued since the agencies released their interagency guidance on June, 9th. The OCC found that American […]
Category: OCC
Interagency Requirements for Third-Party Management Are Finalized
On June 6, 2023, final interagency guidance was issued on managing risks associated with third-party relationships. The guidance provides sound principles that supports a risk-based approach to third-party risk management. It is important that financial institutions include these practices when developing and implementing risk management practices for all stages in the life cycle of third-party relationships. Key Components: Promotes consistency in the agencies’ supervisory approach to third-party risk management. The guidance replaces the Agencies’ existing, […]
2023 HMDA GUIDE
The federal bank regulatory agencies are announcing the Federal Financial Institutions Examination Council’s (FFIEC) revised “A Guide to HMDA Reporting: Getting It Right!” (2023 guide). The 2023 guide provides resources to help banks1 comply with the Home Mortgage Disclosure Act (HMDA) and Regulation C, its implementing regulation (12 CFR 1003). The 2023 guide reflects a technical amendment to the 2020 HMDA rule to adjust the loan volume thresholds effective January 1, 2023,2 for reporting HMDA data on […]
UPDATE ON APPRAISALS AND DISCRIMINATION
On February 14, 2023, the Federal Deposit Insurance Corporation, Consumer Financial Protection Bureau, U.S. Department of Housing and Urban Development, National Credit Union Administration, Federal Reserve Board, U.S. Department of Justice, Office of the Comptroller of the Currency, and the Federal Housing Finance Agency (the “agencies”) sent a joint letter to The Appraisal Foundation (TAF) expressing concerns with the Fourth Exposure Draft of Proposed Changes for the 2023 Edition of the Uniform Standards of Professional Appraisal Practice […]
FEDERAL BANK REGULATORY AGENCIES CONTINUE TO IGNORE SEXUAL ORIENTATION AND GENDER IDENTITY ISSUES
On June 15, 2020, the United States Supreme Court in the case of Bostock v Clayton County declared that disparate treatment based on sexual orientation or gender identity is sex discrimination under federal law. It is the law of the land. On March 9, 2021, the Consumer Financial Protection Bureau (CFPB) issued an interpretative rule to amend Regulation B to clarify that disparate treatment based on sexual orientation or gender identity is sex discrimination under […]