Large Bank Compliance Huddle January 2017

Recent Exams Does anyone currently have examiners on-site? Is there still a continuing increase in request information? What is the focus of the on-site? Has anyone just been through an exam or recently received their ROE? Has examiner “tone” changed from the last on-site? Are the reports giving credit where credit is due, or if there were concerns, are the reports written in such a way that the regulators are seemingly sympathetic or more demanding? What are some of the areas of focus?

HMDA Phases In First Phase: 1/1/17 Primarily affects low volume institutions, not much change for larger institutions Second Phase: 1/1/18 Effective date for most provisions New data collection fields required Third Phase: 1/1/19 Enforcement changes and some additional reporting amendments Last Phase: 1/1/20 Quarterly reporting

HMDA How is your bank preparing for the new data submissions? Do you have the resources to handle the expanded reporting requirements? Are you working with software providers? Any indication if providers will be ready? Budget: how much is this going to cost? Any other concerns?

Enforcement Actions By far the most we see are UDAAP Overdrafts Debt collection Credit cards and credit products Mortgage servicing/foreclosure SCRA

Some Recent Enforcement Actions Wells Fargo Mortgage Servicing: $70 million Sales culture and fake accounts: $35 million JP Morgan Mortgage Servicing: $48 million HSBC Add on credit protection product: $35 million Mortgage Servicing: $32.5 million FNB Omaha Marketing ID protection: $3.5 million and a C&D Order First Niagara Bank Overdraft disclosures: $2 million Sun National Mortgage Banking Activities: $25,000

Anything Else on Your Mind…

Questions? Thank you for your participation and input into the conversation! If you have any additional questions, contact Compliance Alliance at hotline@compliancealliance.com or 888-353-3933.