May 20

Recent Compliance Issues: 5/1/15 – 5/14/15


1. Most banks that offer residential mortgages are preparing for the implementation of the new TILA-RESPA integrated disclosures (TRID) that will take effect starting August 1, 2015. If you are concerned as to whether your preparation strategy is adequate and on schedule, let our former, Federal bank regulators assist you in these efforts and learn best practices for managing the August 2015 TILA-RESPA disclosure deadline.

2. Government officials have stepped up warnings to financial institutions about the practice of redlining when considering loans. The Justice Department opened 25 fair-lending cases last year; of those, 10 were joint cases with the Consumer Financial Protection Bureau (CFPB). It is always prudent practice to have our former, Federal bank regulators review your policies and procedures and analyze your residential mortgage loan portfolio to ensure that your institution is following all Federal fair lending laws and regulations.

3. More merchants and credit card companies are using co-branded credit cards to boost growth. The cards were less popular after the financial crisis. According to some reported statistics, the number of American consumers who had a co-branded credit card last year increased by 13 percent since 2010. If this is a product that your institution promotes, our former Federal bank regulators can review your operations to determine if adequate third- party controls are in place.