CFPB Issues Guidance on Background Screening and File Disclosures in Credit Reporting

Adam Witmer
Regulatory Update

On January 11, 2024, the CFPB issued guidance to consumer reporting companies to address inaccurate background check reports, as well as sloppy credit file sharing practices. In particular, the Bureau issued two advisory opinions with the aim to ensure that the consumer reporting system produces accurate and reliable information and does not keep people from accessing their personal data. 

FDIC Updates its Risk Management Manual of Examination Policies

Adam Witmer
Regulatory Update

On January 5, 2024, the FDIC revised parts of its Risk Management Manual of Examination Policies. The FDIC conducts examinations to help ensure the stability of insured depository institutions by identifying undue risks and weak risk management practices. 

The FDIC revised section 3.1 Asset Quality to to separate FDIC-only explanatory instructions from the specific Uniform Financial Institutions Rating System (UFIRS) Asset Quality component rating language.

The updated RMS manual can be found here.

CFPB Reports Student Loan Payment Resumption Challenges

Adam Witmer
Regulatory Update

On January 5, 2024, the CFPB published an issue spotlight on the CFPB’s oversight of student loan servicing practices in the early months of the resumption of federal student loan repayments after over three years of a payment pause due to the COVID-19 emergency. The report shows that borrowers are encountering long hold times when trying to reach their student loan servicer, experiencing significant delays in application processing times for income-driven repayment plans, and receiving inaccurate billing statements and disclosures.

Happy New Year!

Adam Witmer

Our team at the Compliance Cohort was able to slow down a bit for the holidays, but we are back at it this week and excited about where we are heading in 2024. Over the coming months, we have several new programs planned, starting with our upcoming Winter 2024 Quarterly Compliance Update that will include an overview of the new CRA rule. While the CRA class will be included in our Winter 2024 Quarterly Compliance Update and available to all premium members, it will also be available as a stand-alone class. This program will cover an overview of the new CRA rule that applies to banks, focusing in on how it will affect small and mid-sized banks - so be sure to keep an eye out for more information about this program in the coming weeks. Also in the coming weeks, you will begin to see information about becoming a premium member of the Compliance Cohort. The enrollment period for our premium memberships only happens twice a year (Jan/Feb and July/Aug), so this will be your opportunity to enroll for all of 2024 as a premium member. Speaking of which, we are currently holding a contest to give away one enrollment to our Premium Pro membership - which gives you access to ever single training program in our store - so be sure to find the information on this huge giveaway below and enter for your chance to win. It really is amazing to us how fast 2023 went, but we are excited to roll into 2024 and see what great things will happen in the wonderful world of banking compliance. Happy New Year! -The Compliance Cohort Team-

CFPB Files Amicus Brief Regarding Debt Collection

Adam Witmer
Regulatory Update

On January 2, 2024, the CFPB announced through a blog post that it has filed an amicus brief in the U.S. Court of Appeals for the First Circuit to help ensure consumers can hold debt collectors responsible when they make false representations. The CFPB reiterates that it is a violation against Fair Debt Collection Practices Act to tell consumers that they owe a debt or an amount of money that they don’t actually owe, particularly in medical debt collection.

VIDEO: Unfair Statement Fees

VIDEO: Unfair Statement Fees

Adam Witmer
UDAAP

In this Compliance Clip (video), Adam discusses how financial institutions can avoid a potential unfair act or practice when it comes to assessing statement fees and returned statement fees. Adam explains how this practice can result to a risk of UDAAP violation and shares some steps on how to make sure your financial institution is doing it right. A transcript of this video is now available.

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