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Community Bankers Workshop

Community Bankers Workshop. Consumer Compliance Supervisory Highlights. Scope of Discussion. Flood Insurance. Flood Insurance: Final Rule. Effective July 1, 2019 Key Provisions. Flood Insurance: Mandatory Acceptance.

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Community Bankers Workshop

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  1. Community Bankers Workshop Consumer Compliance Supervisory Highlights

  2. Scope of Discussion

  3. Flood Insurance

  4. Flood Insurance: Final Rule • Effective July 1, 2019 • Key Provisions

  5. Flood Insurance: Mandatory Acceptance • MUST accept if satisfies statutory definition of “private flood insurance”

  6. Flood Insurance: Surplus Lines

  7. Flood Insurance: “At least as broad as”

  8. Flood Insurance: Compliance Aid Assurance statement clause:

  9. Flood Insurance: Compliance Aid Scenario #1 A lender receives a policy that includes the assurance clause. However, the lender noticed that the policy has an unusually high deductible.

  10. Flood Insurance: Compliance Aid Scenario #2 A bank establishes a policy of only accepting policies that include the assurance clause.

  11. Flood Insurance: Compliance Aid Scenario #3 A lender receives a policy with an assurance clause that has language that is similar to, but not exactly the same, as the language in the regulation.

  12. Flood Insurance: Discretionary Acceptance

  13. Flood Insurance: Compliance Aid Scenario #4 The lender receives a policy that does not contain the assurance clause and decides to review using the discretionary acceptance criteria instead of the mandatory acceptance criteria.

  14. Flood Insurance: Mutual Aid Societies • *FDIC is still evaluating how to implement this provision of the final rule

  15. Flood Insurance: Existing Policies

  16. Flood Insurance: Mitigating Risk

  17. Flood Insurance: Effective Date • “Closing” date = day ownership transfers • “Wet funding” vs. “dry funding” states • Nine “dry funding” states:

  18. Flood Insurance: Contents Coverage

  19. Flood Insurance: Force Placed Premiums

  20. RESPA Section 8

  21. RESPA: Core Principles

  22. RESPA: Exam Considerations

  23. RESPA: Marketing

  24. RESPA: Joint Marketing Market value for services/cannot defray costs

  25. RESPA: What is the appropriate split?

  26. RESPA: What is the appropriate split?

  27. RESPA: What is the appropriate split?

  28. RESPA: What is the appropriate split?

  29. RESPA: Marketing Valuation

  30. RESPA: Broker Compensation • Broker compensation must be earned

  31. RESPA: Rental Arrangements

  32. RESPA: Mitigating Risk

  33. Recent Examination Issues

  34. Lines of Credit – Finance Charge Issues

  35. Linked Account Transfers

  36. Deposit Account Benefits

  37. Change-in-Terms Notifications

  38. FDIC’s Consumer Compliance Supervisory Highlights • Articles: • Overdraft Programs: Debit Card Holds and Transaction Processing • RESPA Section 8 Violations • Regulation E – Mistakes Made in the Consumer Liability/Error Resolution Process • Skip-a-Payment Loan Programs • Lines of Credit – Finance Charge Calculation and Disclosure

  39. Resources • FDIC’s Consumer Compliance Supervisory Highlights https://www.fdic.gov/regulations/examinations/consumercomplsupervisoryhighlights.pdf • San Francisco Region’s Quarterly Newsletter Send email to SFConsumerProtection@fdic.gov to subscribe

  40. Resources • Interagency Flood Insurance Update on Private Flood Insurance Rule https://consumercomplianceoutlook.org/outlook-live/2019/interagency-flood-insurance-regulation-update/ • FDIC Financial Institution Letter 44-2008 Third Party Risk, Guidance for Managing Third-Party Risk • CFPB Compliance Bulletin 2015-05 RESPA Compliance and Marketing Services Agreements • HUD RESPA Statements of Policy 1993-3, 1996-1,1999-1, 2001-1

  41. Questions

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