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Large Bank Compliance Huddle

Large Bank Compliance Huddle. January 2017. Recent Exams. Does anyone currently have examiners on-site? Is there still a continuing increase in request information? What is the focus of the on-site? Has anyone just been through an exam or recently received their ROE?

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Large Bank Compliance Huddle

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  1. Large BankCompliance Huddle January 2017

  2. Recent Exams • Does anyone currently have examiners on-site? • Is there still a continuing increase in request information? • What is the focus of the on-site? • Has anyone just been through an exam or recently received their ROE? • Has examiner “tone” changed from the last on-site? • Are the reports giving credit where credit is due, or if there were concerns, are the reports written in such a way that the regulators are seemingly sympathetic or more demanding? • What are some of the areas of focus?

  3. HMDA Phases In • First Phase: 1/1/17 • Primarily affects low volume institutions, not much change for larger institutions • Second Phase: 1/1/18 • Effective date for most provisions • New data collection fields required • Third Phase: 1/1/19 • Enforcement changes and some additional reporting amendments • Last Phase: 1/1/20 • Quarterly reporting

  4. HMDA • How is your bank preparing for the new data submissions? • Do you have the resources to handle the expanded reporting requirements? • Are you working with software providers? • Any indication if providers will be ready? • Budget: how much is this going to cost? • Any other concerns?

  5. Enforcement Actions • By far the most we see are UDAAP • Overdrafts • Debt collection • Credit cards and credit products • Mortgage servicing/foreclosure • SCRA

  6. Some Recent Enforcement Actions • Wells Fargo • Mortgage Servicing: $70 million • Sales culture and fake accounts: $35 million • JP Morgan • Mortgage Servicing: $48 million • HSBC • Add on credit protection product: $35 million • Mortgage Servicing: $32.5 million • FNB Omaha • Marketing ID protection: $3.5 million and a C&D Order • First Niagara Bank • Overdraft disclosures: $2 million • Sun National • Mortgage Banking Activities: $25,000

  7. Anything Else on Your Mind…

  8. Questions? Thank you for your participation and input into the conversation! If you have any additional questions, contact Compliance Alliance at hotline@compliancealliance.com or 888-353-3933.

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