1. Compliance Huddle
may 2017

2. 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?

3. Agenda Exams/Audits Findings HMDA Beneficial Ownership
Compliance Department Structure
Overdraft programs
Redlining – CRA/Fair Lending (REMA)
Anything else on your mind

4. HMDA Continues to be the #1 Requested Topic of Discussion
Do you have the resources to handle the expanded reporting requirements?
Are peers hiring more staff to accommodate change in workload?
Analysis of how many current loan programs that were non-reportable that are now reportable?
If so, what percentage increase are being anticipated? Policies updated, started training of responsible staff?
Has anyone been able to find the platform on the CFPB website?
Any other concerns?

5. Beneficial Ownership System updates? Training? Procedures?
Policy update verbiage?

6. Compliance Department Structure
How many employees in the compliance department??
Separate BSA Officer?
Separate HMDA Officer?
Etc.

7. Overdraft Programs
Are any banks offering an OD program that has “passed regulatory muster”?
What are the parameters?
Automatic or by request?

8. What’s up with Redlining
CRA data integrity exams – what all is involved?
Has anyone been cited with a Fair Lending redlining issue or concern they are willing to talk about?
What is Reasonably Expected Market Area and how does that differ from Lending Assessment area?

9. Anything Else on Your Mind…

10. Questions?
Thank you for your participation and input into the conversation! If you have any additional questions, contact Compliance Alliance at or