On Monday, September 10, 2018, the FDIC released a Financial Institution Letter (FIL-46-2018) seeking comment on a proposal to retire certain FILs to an inactive status.  Specifically, the proposal is targeting 374 of the 664 risk management supervision-related FILs issued over nearly two decades that are considered to either be outdated or that convey regulations or other information that is still in effect but available elsewhere on the FDIC’s website.  

The early bird discount for our Compliance Class on the HMDA partial exemption and the CFPB’s interpretive and procedural rule is ending on Monday, September 17, 2018.  This comprehensive Compliance Class webinar includes: 1) a ready-to-play instructional video, 2) a comprehensive training manual, 3) a step-by-step guide for how to determine eligibility for the partial exemption, 4) an exemption reporting cheat sheet, 5) an executive summary of the rule to share with management or the Board, and 6) a Q&A of frequently asked questions. Those interested in the class can take advantage of an Early Bird special through September 17, 2018 that saves $50 off the regular price and allows early enrollees to submit questions for the final Q&A.

On September 6, 2018, the CFPB released their 17th edition of Supervisory Highlights.  This current edition covers supervision activities from the CFPB during the time period of December 2017 through May of 2018.  This current edition shares observation in the areas of auto loan servicing, credit card account management, debt collection, mortgage servicing, payday lending, and small business lending.  The report also shares a number of public enforcement actions taken with supervised backs as well as providing a discussion on recent Bureau rules and guidance.

HMDA Partial Exemption Resources

In this atypical Compliance Clip (video), Adam explains why those who qualify for the HMDA partial exemption will probably want to use it as quickly as possible. He also manages to relate one of his most embarrassing stories to HMDA.

The FDIC and OCC have each released their lists of CRA performance evaluations from August 2018.  In addition, these agencies - as well as the Federal Reserve - have released their quarterly schedules of planned CRA evaluations for the 4th quarter of 2018 and the first quarter of 2019.  Institutions regulated by the OCC, FDIC, and Federal Reserve can review these schedules to determine whether they are on the planned list of upcoming CRA exams. As we have said before, one of the best

On August 29, 2018, the Federal Reserve hosted a webinar regarding focused on the topic of complaint management titled “Complaints as a Supervisory and Risk Management Tool.”  In this webinar, the Federal Reserve provided an overview of their complaint investigation process and provided an overview of what they look for when investigating complaints.  While this webinar didn’t provide significantly new information, there were a few takeaways from this training, including some guidance on how to manage complaints on social media.