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Financial Services Law Insights and Observations

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  • Banking Agencies Delay Certain Changes to Call Reports

    Consumer Finance

    On May 23, the OCC, the FDIC, and the Federal Reserve Board published a notice to delay certain proposed changes to Call Report data collection pending further consideration of whether and how to proceed with the changes. The notice explains that Call Report revisions related to consumer deposit accounts, including (i) the screening question about an institution's offering of such deposits, (ii) consumer transaction and nontransaction savings deposit account balances for institutions with $1 billion or more in total assets, and (iii) data on certain service charges on consumer deposit accounts, would not take effect before March 31, 2014. Similarly, data collection regarding total liabilities of an institution’s parent depository institution holding company that is not a bank or savings and loan holding company would not take effect before the same date. Certain other changes still will take effect on the proposed June 30, 2013 date, while others will be delayed until the end of 2013.

    FDIC Federal Reserve OCC Bank Supervision

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  • CSBS Releases Annual Report

    State Issues

    On May 2, the CSBS released its 2012 annual report, which aggregates and reviews the organization’s activities in the prior year, identifies future goals for the organization, and outlines specific priorities for 2013. The paper also incorporates more focused reports on past and future activities by various CSBS divisions and boards, including a report from the Policy and Supervision Division that reviews bank supervision, consumer protection and non-bank supervision, and legislative and regulatory policy, including the CSBS positions on community bank regulatory relief and federal proposed capital rules.

    CSBS Community Banks Bank Supervision

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  • CFPB Releases Student Lending Examination Procedures

    Consumer Finance

    On December 17, the CFPB released its Student Lending Examination Procedures, which are an extension of the CFPB’s General Supervision and Examination Manual and will be used as a field guide by CFPB examiners to review student lender compliance with federal consumer financial laws. The Student Lending Examination Procedures are organized in seven modules: (i) Advertising, Marketing, and Lead Generation, (ii) Application, Qualification, Loan Origination, and Disbursement, (iii) Loan Repayment, Account Maintenance, Payoff Processing, and Payment Plans, (iv) Customer Inquiries and Complaints, (v) Collections, Accounts in Default, and Credit Reporting, (vi) Information Sharing and Privacy, and (vii) Examination Conclusion and Wrap-up. Under the first module, for example, CFPB examiners will assess whether a lender’s advertising and marketing practices are deceptive, misleading, or discriminatory by sampling all of the lender’s marketing and advertising materials, including print, electronic and other media, such as the Internet, email and text messages, telephone solicitation scripts, agreements and disclosures. With regard to borrower complaints, examiners will assess, among other things, the systems, procedures, and policies used by a lender for tracking, handling, investigating, and resolving consumer inquiries, disputes, and complaints. The CFPB has the authority to supervise large bank and nonbank student lenders, and, as with its other procedures, the CFPB will use the same examination procedures across both types of institutions.

    CFPB Nonbank Supervision Student Lending Bank Supervision

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  • CFPB Realigns Supervision Team

    Consumer Finance

    On December 17, the CFPB announced a reorganization of part of its Division of Supervision, Enforcement, and Fair Lending. Effective immediately, CFPB staff members responsible for supervision activities are organized in two offices:  Examinations and Policy. Previously, supervision staff were organized into offices for Nonbank Supervision and Large Bank Supervision.  According to the CFPB’s announcement, the Examinations team will (i) recruit, train, and commission examiners, (ii) ensure policies and procedures are followed, and (iii) plan and execute examinations appropriately in light of resources and priorities. The CFPB’s four regional offices will report to the Examinations team, which is being led, on an acting basis, by Paul Sanford. Mr. Sanford had been Acting Assistant Director for Large Bank Supervision. The CFPB explains that its Policy team will ensure that policy decisions for supervision are consistent with both the law and the CFPB’s mission, and that such decisions are consistent across markets, charters, and regions. The Policy team will be further organized by product or service market, rather than by the type of financial institution. Each market team will be responsible for developing supervision strategy and policy across both bank and nonbank markets. Peggy Twohig, formerly the head of the CFPB’s Nonbank Supervision office, will be the Assistant Director of Supervision Policy.

    CFPB Nonbank Supervision Bank Supervision

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