Our Top 5 Compliance Blog Posts of 2014
In case you missed it, here are the five most popular blog posts of 2014. From HMDA Plus to tips for assessing your compliance culture, these are the posts you need to read.
2014 was a big year for regulatory compliance professionals, as we dealt with new regulations, learned from enforcement actions and gained key insights.
Many more changes await on the horizon! From HMDA Plus to the new integrated mortgage disclosure rules, 2015 promises to be a game-changer. We'll be with you every step of your compliance journey, helping to provide clarity and guidance. Before we dive into the new year, let's take a quick look back at our top five most popular compliance blog posts of 2014:
In July, the CFPB released the proposed HMDA Plus changes. This post shares six of the key proposed changes to HMDA reporting requirements. Among these proposed changes are adjustments to the thresholds, new types of transactions covered by HMDA, and increased data reporting requirements. The post also includes a bit of HMDA's history, for context.
We also shared some primary concerns expressed by the industry about these changes. Some have said that the changes could jeopardize borrowers' privacy, while others have expressed concerns about the burden on reporting institutions.
The final HMDA Plus rules are yet-to-be-released, but these proposed changes are excellent foreshadowing of changes to come.
The Office of Fair Lending released some key tips to help institutions avoid being prioritized for a Fair Lending exam by the CFPB. In short, these are five things they will evaluate when determining who to examine.
Included in this list are complaints and tips, supervisory and enforcement history, the quality of the compliance management system, data analysis and market insight.
As we mention in the post, the key takeaway is that financial institutions should be proactive about compliance. It's very important to know your compliance risk exposure, particularly as you prepare for 2015.
A $225 million enforcement action with GE Capital Bank, now known as Synchrony Bank, provided seven important Fair Lending and UDAAP compliance reminders. The CFPB alleged that the bank wasn't making offers equally to Spanish speakers in the US and Puerto Rico. They also found that the telemarketers weren't accurately explaining the credit card add-ons to customers.
The seven key reminders, four for Fair Lending and three for UDAAP, provided by this enforcement action are important to understand. These seven reminders include the importance of consistency across channels to the need to be wary of exclusions. Not surprisingly, many of these align with the regulatory focal points highlighted in the post above.
In this helpful post, we share six ways to evaluate your institution's compliance culture. All of the regulatory agencies, particularly the CFPB and the FRB, have emphasized the importance of a strong culture of compliance. This post shares six simple questions you can ask yourself to evaluate the health of your compliance culture.
As you might expect, leadership and communication are essential. We also shared some questions provided by the FRB that leadership can ask the compliance team to help foster collaboration. As you know, compliance is the ultimate team sport.
Fair Lending regulations apply to all aspects of the credit process, and underwriting is an important risk area. Guided by regulator perspectives learned from an enforcement action between the DOJ and Fifth Third, with Cranbrook Mortgage Corporation as the second defendant. The DOJ claims that Fifth Third discriminated on the basis of receipt of public assistance, though Fifth Third denies the allegation.
This enforcement action, as well as other similar ones, highlight the importance of third-party risk management as well as complaint management. Both are intensely scrutinized by the regulators, and the ultimate responsibility of compliance falls on the the financial institution.
TRUPOINT Viewpoint: We learned a lot in 2014, and we continued to see that the CFPB is leading the regulatory pack. We know that the compliance departments in banks, credit unions, mortgage companies and auto lenders will respond gracefully to the challenges of 2014 and 2015, as they have every year.
It was also an important year for TRUPOINT Partners. This year brought continued growth, new colleagues and consultants, and the opportunity to learn many valuable lessons. We want to thank you for your trust and readership. If you have any questions, we're always just a phone call or email away.