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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.


Top Story Lending Related

09/16/2019

Fannie and Freddie multifamily loan caps revised

The Federal Housing Finance Agency (FHFA) has announced a revised cap structure on the multifamily business of Fannie Mae and Freddie Mac (the Enterprises). The new multifamily loan purchase caps will be $100 billion for each Enterprise, a combined total of $200 billion in support to the multifamily market, for the five-quarter period Q4 2019 – Q4 2020. The new caps apply to all multifamily business – no exclusions.

A Fact Sheet and Revised Appendix A (Conservatorship Scorecard) were also posted.

09/13/2019

FTC charges operators of student loan debt relief schemes

The Federal Trade Commission announced yesterday it has charged the operators of two similar student loan debt relief schemes, and a financing company that assisted them, with bilking millions of dollars from consumers. The defendants allegedly charged illegal upfront fees that they led consumers to believe went toward consumers’ student loans, and falsely promised that their services would permanently lower or even eliminate consumers’ loan payments or balances. The defendants also signed customers up for high-interest loans to pay the fees without making required disclosures.

Complaints against:

09/11/2019

Bureau and states launch innovation network

The CFPB announced Tuesday the launch of the American Consumer Financial Innovation Network (ACFIN) to enhance coordination among federal and state regulators to facilitate financial innovation.

Initial state members of ACFIN are the attorneys general of Alabama, Arizona, Georgia, Indiana, South Carolina, Tennessee, and Utah. All state regulators have been invited to join.

09/11/2019

CFPB issues innovation policies

The CFPB has issued three new policies to promote innovation and facilitate compliance: the No-Action Letter (NAL) Policy, Trial Disclosure Program (TDP) Policy, and Compliance Assistance Sandbox (CAS) Policy.

No-action letters provide increased regulatory certainty through a statement that the Bureau will not bring a supervisory or enforcement action against a company for providing a product or service under certain facts and circumstances. The Bureau has issued its first NAL under the new NAL Policy in response to a request by HUD on behalf of more than 1,600 housing counseling agencies (HCAs) that participate in HUD’s housing counseling program. The no-action letter essentially states that the Bureau will not take supervisory or enforcement action under RESPA against HUD-certified HCAs that have entered into certain fee-for-service arrangements with lenders for pre-purchasing of housing counseling services. The Bureau also released a No-Action Letter Template for mortgage lenders to apply for a NAL for any HUD-required MOU between the mortgage lender and a participating counseling agency under a Housing Counseling Funding Agreement.

Under the new TDP Policy, entities seeking to improve consumer disclosures may conduct in-market testing of alternative disclosures for a limited time upon permission by the Bureau.

The CAS Policy enables testing of a financial product or service where there is regulatory uncertainty. After the Bureau evaluates the product or service for compliance with relevant law, an approved applicant that complies in good faith with the terms of the approval will have a “safe harbor” from liability for specified conduct during the testing period. Approvals under the CAS Policy will provide protection from liability under the Truth in Lending Act, the Electronic Fund Transfer Act, or the Equal Credit Opportunity Act.

UPDATE: The policies were published in the Federal Register 9/13/2019:
NAL policy: 84 FR 48229
TDP policy: 84 FR 48260
CAS policy: 84 FR 48246

09/11/2019

FDIC updates manuals

The FDIC has released the September 2019 updates to its Risk Management Manual of Examination Policies. Section 3.2 (Loans) has been updated with revised loan evaluation instructions, technical updates for accounting, appraisal thresholds, syndicated lending instructions, and various technical edits to update terminology.

The FDIC also announced the September updates to its Compliance Examination Manual. Section IV-3.1 (Fair Lending Scope and Conclusions Memorandum) was revised to reflect changes to pre-examination interview questions and information requests made during the examination planning proceess, and Section V-6.1 (Flood Disaster Protection) was updated to incorporate the private flood insurance final rule’s provisions pertaining to the mandatory and discretionary acceptance of private flood insurance by financial institutions, the qualification process and acceptance of mutual aid society plans in satisfaction of the flood insurance purchase requirement; and minor technical changes.

09/10/2019

OCC schedules 2 LA workshops

The OCC has announced it will host two workshops at the Federal Reserve Bank of Los Angeles, October 22 and 23, for directors of institutions supervised by the OCC:

  • The Compliance Risk workshop on October 22 focuses on the critical elements of an effective compliance risk management program. Topics of discussion include the Bank Secrecy Act, Flood Disaster Protection Act, Fair Lending, Home Mortgage Disclosure Act, Community Reinvestment Act, and other compliance hot topics.
  • The Operational Risk workshop on October 23 focuses on the key components of operational risk—people, processes, and systems. The workshop also covers governance, third-party risk, vendor management, internal fraud, and cybersecurity.

09/10/2019

July G.19 Consumer Credit data

The Federal Reserve System has released July 2019 G.19 Consumer Credit data. Consumer credit increased at a seasonally adjusted annual rate of 6-3/4 percent. Revolving credit increased at an annual rate of 11-1/4 percent, while non-revolving credit increased at an annual rate of 5-1/4 percent.

09/10/2019

Fed CRA evals released in August

Our review of the Federal Reserve's CRA evaluation ratings reveals that 18 ratings were made public in August. Sixteen institutions were rated Satisfactory. Two institutions received Outstanding ratings (links are to their evaluation reports):

09/09/2019

CFPB files complaint against CFLA, Lehman, and Carrigan

The Consumer Financial Protection Bureau announced on Friday it has filed a complaint in federal court in the Central District of California against Certified Forensic Loan Auditors, LLC (CFLA), Andrew Lehman, and Michael Carrigan. The complaint alleges that CFLA and Lehman have engaged in deceptive and abusive acts and practices and have charged unlawful advance fees in connection with the marketing and sale of financial advisory and mortgage assistance relief services to consumers.

CFLA is a foreclosure relief services company incorporated in California and headquartered in Houston, Texas. Lehman is CFLA’s president and CEO. The Bureau’s complaint alleges that Carrigan, who was the company’s sole auditor, provided substantial assistance to CFLA and Lehman. Concurrent with the complaint, the Bureau and Carrigan filed a proposed stipulated final judgment and order to resolve the substantial assistance claims against Carrigan.

09/09/2019

FTC challenges $1.2B merger of title insurance providers

The Federal Trade Commission has issued an administrative complaint seeking to block title insurance provider Fidelity National Financial, Inc.’s $1.2 billion acquisition of Stewart Information Services, alleging the merger would substantially reduce competition in state markets for title insurance underwriting for large commercial transactions, and in several local markets for title information services.

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