1. Large Bank Compliance Huddle
January 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. 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

4. 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?

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

6. 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

7. Anything Else on Your Mind…

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