Compliance Blog

Written by Sarah Loats Zimmermann

OCC ODP proposed guidance. Another federal agency is jumping on the ODP guidance bandwagon. The OCC issued proposed supervisory guidance last week. This guidance, if finalized, would not apply to credit unions, but for those of you following the ODP guidance issue, it's one more sign of the times.  Reviewing the OCC's proposed guidance, it doesn't appear to have specific guidelines. For example, in relation to consumer usage of ODP, the OCC proposed guidance suggests that banks should establish prudent limitations and monitor accounts for excessive usage; however, it does not indicate a specific limitation (the FDIC's guidance states that if a consumer overdraws an account 6 times where a fee is charged in a 12-month period, the bank should contact the consumer to discuss less costly alternatives). It does however list several ODP practices it is concerned with, including excessive reliance on ODP fee income, lack of responsible limits on customer costs and usage, and failure to monitor promotional practices for potentially misleading statements. Again, this guidance wouldn't apply to credit unions, but you may want to keep it in the back of your minds when discussing your own ODP programs.

CFPB. Elizabeth Vale is the Assistant Director for Community Banks and Credit Unions at the CFPB (so, an important person for us). Yesterday, she blogged about the outreach the CFPB has made to community banks and credit unions regarding the inital proposed TILA/RESPA combined forms.

Flood. Last week, the Senate Banking Committee held a hearing on the reauthorization of the NFIP program. As you may know, the program is set to expire on September 30 this year, so Congress will need to reauthorize the NFIP before then in order to avoid another lapse.