Compliance Blog

Posted by Anthony Demangone

Happy Friday, everyone.  When I asked what folks wanted us to focus on next, the response was overwhelming: HOEPA.  And that makes sense, as the compliance deadline kicks in October 1.  In second place came RESPA.  So, we'll focus on HOEPA first.  Once we finish that, we'll move on to RESPA. 

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The GAO has issued a report critical of federal regulator enforcement of fair lending laws.  Here are a few things I noted:

• First, I became aware of this issue after receiving a press release from the House Committee on Financial Services.  In other words, those with the power to lean on regulators and hold hearings are drawing attention to the report.
• The report points to inconsistencies in enforcement.  One line, on page 41, really caught my attention.  

  Finally, depository institutions under the jurisdiction of FDIC, Federal Reserve, and OTS were far more likely to be subject to referrals to DOJ for potentially being at heightened risk for fair lending violations than those under the jurisdiction of NCUA and OCC.

What does this mean?  It is hard to say.  But if regulators start getting beat up over this report, you can bet that there will be greater attention on this issue.  And that mean potentially more fair lending exams.

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• Thanks to those who responded to my call for help regarding their most recent BSA exam.  I've received a good number of emails, which will certainly help me prepare for the September 30 BSA roundup.  (The session is available to all, including non-NAFCU members.) But I'd love to hear from more of you!
• Here's a freebie that might interest some of you.  On Tuesday, August 25, I'll conduct a webinar to give an overview of NAFCU's new Volunteer and New Staff Online Training program.  The webinar is free, and those who sign up will get a free 3-day trial subscription to kick the training program's tires. And all are welcome to take advantage - including non-NAFCU members. The program does have a BSA module for volunteers and new employees. 

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Have a great weekend, everyone!