Archive

COMPLIANCE RISK – READING BUT NOT ACTING

In late 2017 the FDIC’s Dallas Region Quarterly Newsletter contained an article entitled Automated Overdraft Program and One-Time Debit and ATM Opt-In Procedure Considerations. The article described a situation observed in several examinations regarding overdraft programs and the interplay with Regulation E opt-in requirements. The well-written article concluded with the following admonition, “If you self-identify violations or potential issues described in this article, management should immediately modify procedures to prevent consumer harm, identify any customers […]

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GUIDANCE ON VOLUNTARY PRIVATE EDUCATION LOAN REHABILITATION PROGRAMS

On February 4, 2019 the Federal Deposit Insurance Corporation (FDIC) issued a Financial Institution letter (FIL-5-2019) dealing with voluntary private education loon rehabilitation programs. The notice was issued jointly with the Board of Governors of the Federal Reserve System (Fed). The FIL is designed to make financial institutions aware of an amendment to section 623 of the Fair Credit Reporting Act (FCRA). This amendment is contained in section 602 of the Economic, Growth, Regulatory Relief […]

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PRIVATE FLOOD INSURANCE FINAL RULE ANNOUNCED

The Office of the Comptroller of the Currency, Board of Governors of the Federal Reserve System, Federal Deposit Insurance Corporation, Farm Credit Administration, National Credit Union Administration have issued a final rule amending their regulations regarding loans in areas having special flood hazards to implement the private flood insurance provisions of the Biggert-Waters Flood Insurance Reform Act of 2012 (Biggert-Waters Act). Prior to implementing this final rule, the agencies issued two proposed rules addressing private flood […]

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FDIC’S AFFORDABLE MORTGAGE LENDING GUIDE

Recently the FDIC published the Affordable Mortgage Lending Guide (Guide). The Guide: Provides community banks with a practical reference tool to compare federal programs so they can make an informed decision about which programs might be the right fit for their business plans and strategies to improve lending options available for their communities. Describes programs from the U.S. Department of Housing and Urban Development (HUD) and its Federal Housing Administration (FHA), the U.S. Department of […]

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REQUEST FOR INFORMATION ON SMALL DOLLAR LENDING

On November 14, 2018 the FDIC  issued a nine-page request for information on small dollar lending, including steps that can be taken to encourage FDIC-supervised financial institutions to offer small-dollar credit products that are responsive to customers’ needs and that are underwritten and structured prudently and responsibly. The request was issued as FIL-71-2018. Comments will be accepted for 60 days following publication in the Federal Register, which is expected soon. The FDIC recognizes the important […]

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