Recently the federal financial institution regulatory agencies released updated Regulation Z Examination procedures. The revised interagency examination procedures reflect amendments implementing revisions to the Truth in Lending Act under the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank Act) that: (1) restrict mandatory arbitration agreements in mortgage loans; and (2) revise existing escrow requirements on first-lien higher-priced mortgage loans. These amendments are effective with respect to transactions for which the creditor receives an application […]
Tag: Compliance Examinations
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 […]
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 […]