When it comes to the Military Lending Act, one the best things you can do is obtain the safe harbor. Financial institutions must verify the status of the applicants by one of two ways: obtaining their status from the DOD's database or pulling a credit bureau report from a nationwide reporting agency.
Of the countless fair lending reviews I’ve conducted as an examiner and consultant over the past dozen years, I’ve noticed that some compliance professionals know a few things about fair lending. They understand why following a rate sheet is important, they may complete secondary reviews of adverse action notices, and they may be involved with reviewing and approving marketing materials.
Read MoreMaybe forgotten isn't always the right word; perhaps "unknown" is more appropriate. I can't tell you how many banks I've been to that had no idea this regulation even exists. The good thing is that it's not very hard to set up a program to comply.
Read MoreOverdraft (OD) issues seem to be on an uptick again. Many bankers have told me recently that the regulators are still focusing on consumer harm with overdraft programs. So what issues are they finding? Well much of it has to do with the way the program is disclosed vs. the way it’s actually charging customers.
Read MoreWhile there are several reasons why the number of banks is declining, it’s likely to continue. Brick and mortar locations are starving for customers, but people aren’t walking through the door anymore. Why? Because they don’t have too.
I’ve been through the examination process nearly a hundred times as an FDIC examiner. I’ve compiled my Top 6 list of simple things you can do to set your bank up for greater success on your next compliance exam. Many of them don’t cost anything, just a little bit of effort.
Read MoreHere is something I’ve heard all too often from bankers: “The examiners say that we need to do more for fair lending, but we just don’t know what to do.” Sound familiar?
Read MoreThere is a major compliance issue still circling around the industry for tiered interest checking accounts. The basic premises are that banks are incentivizing their customers to use their debit cards. They do this by offering a higher APY on checking account balances if a customer uses their debit card so many times a month. The problem lies in how they are disclosing the transaction requirements to their customers.
Read MoreTraditional audits are expensive and often just give you a history report. Most smaller banks don’t ever hire outside help because they feel they can’t afford it. I want to change that. I’ve been an examiner, a bank compliance officer, and an auditor. I believe in sharing those experiences. My vision is to train your staff during my reviews and teach them new ideas and concepts.
Read MoreOver the years, I’ve heard bankers talk about self-identified issues and whether or not they should bring them up to the exam team. They think they will get hit over the head a second time by revealing issues they identified. They are worried the examiners will dig deeper, find more issues, and cost the bank more time and money or that violations will be cited. I want to put some of these myths to bed and give you some advice to make sure that doesn’t happen.
Read MoreI know this may sound a little crazy, but there are some difficult examiners out there. This article is not an attack on examiners; I was an examiner for 6 years. It was the best job I ever had. Lucky for me, I worked with a great team of people, but I’ve seen some unpleasant experiences and heard many stories over the years of examiners not handling interactions with bankers tactfully and vice versa.
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