Compliance Blog

Apr 09, 2012

Consumer Compliance Outlook: Common Compliance Violations

Written by Steve Van Beek

Hope everyone had a great weekend - below is a great resource that might be useful.

Consumer Compliance Outlook.  The Philadelphia Federal Reserve publishes a Quarterly Consumer Compliance Outlook that is usually a valuable resource.  This month's material is especially useful as they walk through common compliance issues seen during examinations.  The PDF of the 1st Quarter 2012 Issue is here and includes: 

The Commonly Cited Compliance Violations include:

  • Regulation B's requirement for joint intent for joint credit (spousal signatures);
  • Regulation B's adverse action notices (lacking content and specificity);
  • RESPA's Tolerance Cures;
  • Reg C/HMDA Rate Spread, Loan Purpose Definitions and Type of Action Taken; and
  • Reg Z Account Opening Disclosures for Open-end Credit. 

We'll look at some of these violations in more detail later this week.  

For now, I'm just glad the Philadelphia Federal Reserve has continued this publication even though authority for the consumer regulations passed to the CFPB.  In the future, I'm hoping the CFPB (and NCUA) realize how useful an informal publication like the Consumer Compliance Outlook can be in highlighting common issues and explaining the requirements to increase compliance among financial institutions.