Archive

CFPB SUPERVISION AND EXAMINATION MANUAL

On October 14, 2011 the Consumer Financial Protection Bureau (CFPB) published it’s Supervision and Examination Manual. The CFPB will begin it’s first examinations in the next few weeks. The publication of the manual is a big deal, but is it a big deal for your institution? Probably not. The CFPB only examines institutions with more than $10 billion in assets, that group includes a little over 100 banks nationwide. So, if you are in that […]

Current Events

I spent the past two days as part of the panel at the BankersonLine.com annual Lending Compliance Triage Conference in Louisville, KY. We had two long days of presentations and discussions. We had many banks with us at the meeting site, and many more participating remotely. Joining me on the panel were Mary Beth Guard, Andy Zavoina and John Burnett of Bankersonline.com, Carl Pry of Key Bank, Kathleen Blanchard of Key Compliance Services, and Lucy […]

THE POLITICAL CIRCUS

The Dodd-Frank Act is one the most significant pieces of legislation to ever impact the banking industry. Our lives would be much simpler if the law never happened, but the law did happen and we all have to deal with it. Instead of dealing with the law in a quick decisive manner Congress and the current administration have turned it into a political circus. Dodd-Frank became law on July 21, 2010. The law contains hundreds […]

REGULATION Z – LOAN ORIGINATOR COMPENSATION RULES

Everyone seems aware that Regulation Z rules, which were effective on April 1, 2011, state that no loan originator shall receive and no person shall pay to a loan originator, directly or indirectly, compensation in an amount that is based on any of the transaction’s terms or conditions. Everyone also seems aware that the term “compensation” includes salaries, commissions, and any financial or similar incentive provided to a loan originator that is based on any […]

AGENCIES REPEAL PROHIBITION ON PAYING INTEREST ON DEMAND ACCOUNTS

Both the Federal Reserve Board and the Federal Deposit Insurance Corporation published final rules repealing regulations that prohibited payment of interest on demand deposits, effective July 21, 2011. The Federal Reserve Board’s Regulation Q was repealed on July 12, 2011. The FDIC’s Part 329 was repealed on July 6, 2011. The regulations had been in place since 1933. The repeals were required by Section 627 of the Dodd-Frank Wall Street Reform and Consumer Protection Act […]