Does anyone have any feedback on what your compliance team is currently focusing on or other "hot topics"? Obviously, HMDA and it seems like Flood is always on the list. Trying to work on some topics to help better train staff and focus our internal reviews.

The agencies released a joint webinar in early December on fair lending hot topics.

I wrote a summary of the hot topics from that webinar here: www.compliancecohort.com/blog/joint-webinar-on-fair-lending-hot-topics

I agree with Fair Lending and would add Complaints to the list of hot topics.

Besides those two topics, our recently finished FRB exam also focused on our Compliance Culture and the 'tone from the top down' as important issues in our Compliance Management System. It was a focal point for them from the initial contact through the exit meeting.

UDAAP

Do any FDIC banks feel like they are still focusing on overdraft?

And has anyone gotten any SPECIFICS when it comes to what they want for Fair Lending. I've heard colleagues say "they want us to do a Fair Lending review/audit/analysis" -- but of what? The examiners never seem to give much direction.

Overdraft isn't just an FDIC thing. We had an FRB exam a few months ago and the topic of fees assessed based on how we pay pre-auths and on what balance came up quite a bit. As far as Fair Lending, there was a heavy focus on consumer lending (mainly auto and equities) and we were questioned on how we monitored exceptions on these products.

For fair lending, does your bank understand and manage the process, or are the results by happenchance?

Do you know where your advertising goes?
Is there LO discretion on underwriting or pricing?
Where your apps and loans are?
Does someone look at the results/demographics, lending patterns, 2nd review, or is it all accidental?

Fair Lending and UDAAP concerns