FAQs on Compliance Management
CDFI’s are mission-driven financial institutions that have been certified by the U.S. Department of the Treasury’s CDFI Fund. CDFIs include credit unions, banks, loan funds, and venture capital funds that operate with a primary mission of serving low-income communities.View CDFI Cert List >
If you've grown over the threshold, begin acting as if you are a large bank. You'll want to start looking more closely at community development. Make sure you're investing resources on this aspect of CRA. Next, start considering how you are going to collect and transmit data to the FFIEC at year end. Make sure you have a process for collecting revenues for your small business and small farm loans and determine whether your number of small business and small farm loans is something that you can handle using the free data collection software from the FFIEC, or if you need additional software.
A community development loan has a primary purpose of community development and has not been reported or collected by the bank or an affiliate for consideration in the bank’s assessment.Learn More >
Consumer loans use the borrower's address. Real estate loans should be geocoded to the location of the property. Business and farm loans should be geocoded to either the location of the borrower's main business facility or to the location where the funds will be used as indicated by the borrower. Be consistent.
While the OCC does not provide guidance on specific information collected from vendors, you may want to outline this in your Vendor Management Policy. Critical vendors at a minimum are recommended, but you may want to take a different approach such as vendors who your FI spends a substantial amount of funds could be the ones you focus D&I efforts on. As long as your FI can confidently describe its reasoning for selection (through documentation), that is the goal.
UDAAP risk assessments are not necessarily a “regulatory requirement”, but they are certainly a supervisory expectation of the CFPB, the OCC and other Federal regulators. In a recent CFPB enforcement action, the CFPB took the novel step of ordering a national bank to develop “a written, enterprise-wide UDAAP risk-management program for any consumer financial products or services” it offers.