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How to add predictive analytics into your risk program. Risk reports are often limited to historical insights and issues and do not provide guidance and insights into the future of the organization. Adding predictive analytics can allow your organization to detect emerging risks and create mitigation plans. This can be achieved by combining internal and external key risk indicators (KRIs) and key performance indicators (KPIs) with regulatory intelligence. This ensures that risk reports can detect more issues and highlight areas of concern. Click here to learn more.

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Consumer credit expands

According to G.19 Consumer Credit data posted by the Federal Reserve yesterday, consumer credit increased in August at a seasonally adjusted annual rate of 5-1/4 percent. Revolving credit decreased at an annual rate of 2-1/4 percent, and nonrevolving credit increased at an annual rate of 7-3/4 percent.


$400,000 residential appraisal threshold effective October 9

The OCC, FDIC and Federal Reserve have published [84 FR 53579] in today's Federal Register the previously announced final rule increasing to $400,000 the threshold for requiring an appraisal by a state certified or licensed appraiser for residential real estate transactions. The portions of the rule increasing the appraisal threshold become effective on October 9, 2019.


FDIC issues 5 outstanding CRA ratings

The FDIC has released a list of banks recently evaluated for compliance with the Community Reinvestment Act. Of the 77 banks listed, 71 received Satisfactory ratings, and one bank was rated Needs to Improve. We congratulate five banks that received Outstanding ratings (links are to their evaluations):


OCC CRA evaluations released

A list of Community Reinvestment Act performance evaluations that became public in September has been released by the OCC. Of the 35 evaluations listed, 21 are rated satisfactory, and one is rated needs to improve. Our congratulations to this "baker's dozen" of banks that received an outstanding rating (links are to PDF copies of the banks' evaluations):


2020 NMLS annual renewal reminder

The NMLS 2020 annual renewal period for federal registrations begins November 1, 2019. Federal regulations require all mortgage loan originators actively registered prior to July 1, 2019, to renew their registrations for 2020. The renewal period ends December 31, 2019. The Federal Registry Resource Center Renew-Reactivate page has guidance on how to prepare for and complete a renewal.


Fed amends Regulations A and D

The Federal Reserve Board has published final rules with amendments to adjust the interest rates for primary and secondary credit from the Reserve Banks (Regulation A) and the interest paid by the Reserve Banks on required and excess reserve account balances (Regulation D).


Fed CRA evaluations for September

A review of the Federal Reserve Board's Community Reinvestment Act search page shows that the Board made public 21 evaluation ratings in September. Our congratulations to Bank of Clarke County, Berryville, Virginia, with a CRA Evaluation that received a rating of "Outstanding." The other 20 banks received "Satisfactory" ratings.


2020 OCC bank supervision operating plan

The OCC has released its bank supervision operating plan for fiscal year 2020. Supervisory strategies will focus on—

  • cybersecurity and operational resiliency
  • BSA/AML compliance management
  • commercial and retail credit underwriting practices and oversight and control functions
  • impact of changing interest rate outlooks on bank activities and risk exposures
  • preparedness for the current expected credit losses (CECL) account standard, and preparation for the potential phase-out of LIBOR
  • technological innovation and implementation


CFPB and SC sue high rate loan brokers

The CFPB announced Tuesday that the Bureau and the South Carolina Department of Consumer Affairs have filed a lawsuit in federal district court in the District of South Carolina against Katharine Snyder, Performance Arbitrage Company, Inc., and Life Funding Options, Inc. The companies, owned and operated by Snyder, brokered contracts offering high-interest credit to veterans, many of whom are disabled, and to other consumers. The Bureau alleges that the companies and their owner violated the Consumer Financial Protection Act’s prohibition against deceptive acts or practices.The Bureau and South Carolina allege that Snyder and her companies—

  • misrepresented to consumers that the contracts the companies broker are valid and enforceable when, in fact, the contracts are void under federal and state law;
  • misrepresented to consumers that the product is a sale of payments and not a high-interest credit offer; and
  • failed to inform consumers of the products’ interest rates.

The complaint seeks an injunction against Snyder and her companies, redress to consumers, and the imposition of a civil money penalty.


OCC reports slight improvement in mortgage performance

The OCC has releaased its Mortgage Metrics Report, Second Quarter 2019. It shows 96.1 percent of mortgages included in the report were current and performing at the end of the quarter, compared to 95.6 percent a year earlier. It also showed that servicers initiated 21,409 new foreclosures during the second quarter of 2019­, a 22.5 percent decrease from the previous quarter and a 27.7 percent decrease from a year ago. Servicers completed 15,683 mortgage modifications in the second quarter of 2019, and 71.7 percent of the modifications reduced borrowers’ monthly payments.


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