The Compliance Management Program and Understanding the Examination Process
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1 The Compliance Management Program and Understanding the Examination Process Bank Operations Institute October 17, 2013 Annette Schindler FDIC Lauri Angle- FDIC Molly McKnight - OCC Diane van Gelder Federal Reserve Bank of Dallas 1
2 Disclaimer The opinions expressed are the speaker s and not those of the Federal Reserve System, the Federal Reserve Bank of Dallas, OCC or the FDIC. The information provided today is an overview of some of the consumer protection laws and regulations. It is not intended to be all encompassing. Please refer to the actual regulations and your agency s examination guidance for more information. 2
3 Topics Compliance Management Program The Examination Process Community Reinvestment Act 3
4 4 Compliance Management Program
5 Compliance Risk Management Program Understand operations, products, and customers Benchmarks used to track performance Identify Measure Monitor Controls Audits, reviews, MIS Polices, standards, limits, training 5
6 Responsibilities Board Vision Policy Oversight Ask Questions Management Strategic plan & goals Implement policy MIS & control process Analysis to support answers 6
7 Program Components Policies and Procedures Information needed to perform staff responsibilities Consistent operating guidelines Monitoring Exception tracking Trends Training Tailored to bank s operations Test effectiveness Audit/Review Internal or external but must be independent Adequate scope and intensity Corrective action Reporting to board Complaints 7
8 Compliance Program By business line By regulatory requirements By product and services By staff 8
9 Compliance by Business Line Don t forget to include: Consumer loans and leases Commercial loans Mortgages Deposit Operations Trust Non-deposit products Indirect products offered through 3 rd party Marketing 9
10 Compliance by Regulation Both State and Federal Regulations apply to multiple products and business lines Regulation change 10
11 Lending Regulation Truth-in-Lending HOEPA RESPA FDPA ECOA and FHA SCRA Consumer Leasing Act Talent Amendment HOPA HMDA Usury FDCPA SAFE Act Protecting Tenants in Foreclosure Reg O 11
12 Deposit Regulations Truth-in-Savings Electronic Fund Transfer Act Expedited Funds Availability Act Reserve Requirements of Depository Institutions FDIC Insurance Processing requirements Federal Reserve NACHA Visa/MasterCard 12
13 Other Regulations FCRA FACT Act BSA USAPATRIOT Act UDAP/UDAAP Privacy RTFPA COPPA Illegal internet gambling Nondeposit Products CRA and CRA Sunshine Riegle-Neal Interstate Banking and Branching Efficiency Act E-Signature Act CANSPAM Telephone Consumer Protection Act IRA Rules Stored value cards Durbin amendment 13
14 Compliance By Products/Services Don t forget all your delivery channels Be involved early in new product development Periodically reevaluate products/services Be aware of technological advances 14
15 Compliance by Staff Appropriate staff with adequate authority and time Make sure all staff is aware of and accountable for compliance obligations Training, internal controls, and procedures 15
16 Rate the Compliance Management Risk 1. A $50 million bank has few written procedures 2. The bank has a compliance committee 3. The compliance officer has lending authority 4. The external auditors only review for technical compliance of the fair lending regulations 16
17 Rate the Risk 5. Annual fair lending training is provided to all staff and Board of Directors 6. Loan policies provide detailed guidance on the pricing of underwriting and pricing of consumer loans. Exceptions to policy are not tracked or monitored. 17
18 What are Compliance Examinations? Tool to measure compliance with federal consumer protection laws Lending regulations Deposit regulations Fair lending statutes and regulations Community Reinvestment Act 18
19 Approach to Compliance Examinations Risk-focused Tailored to bank s operations More attention for areas of highest risk Transaction testing for areas of highest risk 19
20 The Examination Process? Pre-examination planning - several months prior to scheduled onsite exam date Tailored to bank Questionnaire Data requests Interviews Onsite Entrance meeting Transaction test and exam review work Ongoing communication Exit meeting(s) Post examination Report preparation Enforcement Actions (if applicable) 20
21 The Examination Process The Examination Process 21
22 What Do Examiners Ask For Description of the compliance management program Audits and reviews Policies and procedures Training Loan trial balance Consumer disclosures Samples of loan and deposit transactions Board and committee meeting minutes 22
23 23 Bank s Responsibilities for an Exam
24 Exam Management Tips Familiarize yourself with examination procedures Make sure to address pre-examination requests in timely manner Ensure Board has approved any policy / program changes Review the previous examination report Communicate about the exam with bank staff 24
25 Tips Review and address any consumer complaints Develop a routine for managing the onsite portion of the examination Assign responsibility for corrective action Respond promptly to examination report findings 25
26 Dealing with Regulatory Change Keep abreast of regulatory changes Know how your bank will be affected Modify policies and procedures Implement system changes Test all systems and review disclosures Modify audit and monitoring procedures Train, train, and then train some more 26
27 27 Community Reinvestment Act
28 Goal Encourages depository institutions to meet the credit needs of its communities Including low- and moderate-income neighborhoods Including low- and moderate-income borrowers and businesses/farms of different sizes Must be consistent with Safe and Sound operations 28
29 Evaluation Types Small Bank < $296 million total assets Intermediate Small Bank(ISB) Assets between $296 million and $1.186 billion for the preceding two year ends Large Bank Assets > $1.186 billion for the preceding two year ends Asset thresholds adjusted annually 29
30 Evaluation Frequency Prior CRA Rating Assets < $250 Assets >$250 Outstanding After 60 months Within 36 months Satisfactory After 48 month Within 36 months Needs to Improve Within 36 months Within 36 months Substantial Non Within 36 months Within 36 months Compliance
31 Special Examination Types Wholesale or Special Purpose i.e. credit card banks Strategic Plan 31
32 Small Bank Performance Standards Loan to deposit ratio Assessment area concentration Must have >50% of loans inside assessment area(s) for satisfactory rating in this criterion Record of lending to borrowers of different income levels and businesses/farms of different sizes Geographic distribution of loans Response to written CRA complaints 32
33 ISB Performance Standards Small Bank lending test Community development test Extent and responsiveness of CD services CD loans Qualified investments Must receive at least a satisfactory rating on both tests to receive overall satisfactory rating 33
34 Large Bank Performance Standards Lending Test Considers same criteria as small bank, plus Community development lending Use of innovative or flexible lending practices Service Test Retail banking services Record of providing community development services Investment Test Record of providing qualified community development investments 34
35 Performance Context Evaluation of institution s activities is based on the performance context Different for each institution Considers factors such as Financial condition Size Assessment area demographics Assessment area needs 35
36 Ratings Small Bank and ISB Outstanding Satisfactory Needs to Improve Substantial Noncompliance ISBs assigned an overall rating and one for the Lending Test and CD Test Noncompliance with the substantive provisions of the fair lending laws and illegal credit practices may impact overall rating 36
37 Ratings for Large Banks Ratings assigned for the Lending, Service and Investment Test Each rating assigned a point value Lending Test weighted more heavily Composite rating assigned based on total points assigned component tests Noncompliance with the substantive provisions of the fair lending laws and illegal credit practices may impact overall rating 37
38 Large Bank Component Ratings Component Test Lending Investments Services Outstanding High Satisfactory Low Satisfactory Needs to Improve Substantial Noncompliance
39 Large Bank Composite Rating Points Composite Rating 20+ Outstanding Satisfactory 5-10 Needs to Improve 0-4 Substantial Noncompliance 39
40 2010 Census Data 2012 and later data reported using 2010 census tract identifiers Use of American Community Services (ACS) median family income HUD s estimated MFI will be replaced with ACS MFI OMB released new MSA designations tins/2013/b pdf 40
41 Community Development Affordable housing for low- or moderate-income (LMI) individuals Community services for LMI individuals Activities that promote economic development by providing financing for small businesses or small farms Activities that revitalize or stabilize LMI geographies, distressed or underserved non-metro middle-income areas, or designated disaster areas Activities that support, enable or facilitate projects or activities that meet eligible uses criteria described in Section 2301(c) of the Housing and Economic Recovery Act of 2008 (HERA) and are conducted in designated target areas identified in plans approved by HUD in accordance with the Neighborhood Stabilization Program (NSP) 41
42 Is this Community Development 1. $500,000 working capital loan to commercial developer to build 12 unit apartment building in a moderate-income census tract 2. EVP serves as President and Treasurer of the YMCA - Programs serve the needs of LMI and include an after school program for children in which financial literacy training is provided by bank employees 42
43 Is this Community Development (Continued) 3. $100,000 Contribution - Small business loan pool to fund micro loans. Branch manager is a member of the board 4. The branch manager is deacon in his church. He provides a variety of information and free services designed to help elderly members 43
44 Is this Community Development (Continued) 5. The bank has an opportunity to provide working capital financing to the local Economic Development Corporation to build a facility to attract new manufacturing companies. 6. Bank president serves as founder of the Arts Foundation which promotes growth of Arts, Culture, and Recreation 44
45 Is this Community Development (Continued) 7. The bank participates in the United Way s funding raising drive. Bank employees donate $30,000 for the United Way 8. In addition to the employee s donations, the bank makes an unrestricted donation to the United Way. 45
46 46 Questions??
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