Consumer Compliance Violations

Two states in the 10th District (Wyoming and Oklahoma) are exempt from Chapters 2 and 5 of the Federal Truth in Lending Act, and applicable portions of Regulations M and Z.  The results of the list may be skewed due to these exemptions.

Violations of Law Most Frequently Identified in 2019 Examinations

Of the 45 consumer compliance examinations conducted in 2019, violations of law were identified in 22 (49%) of the banks examined.
Regulation Violation % of Banks
Regulation B Failure to record and retain documentation evidencing applicants' intent to apply for joint credit. Failure to notify applicant within 30 days of completed application of approval, counteroffer or adverse action. 64%
HMDA Incorrect data reporting 41%
Regulation Z Inaccurate disclosure of APR 23%
FCRA Failure to notify the use of credit report in adverse action 9%

Consumer Compliance Program Weakness

Most commonly identified areas of weakness in the compliance management programs of Banks within the 10th District.

Compliance Management System Weakness Most Identified in 2019

Of the 45 consumer compliance examinations conducted in 2019, 17 resulted in supervisory follow-up.
Fair Lending Underwriting and pricing discretion, managing redlining risk 76%
Board and Management Oversight Resources devoted to managing compliance risk, lack of adequate compliance risk awareness 35%
Address Violations of Law and Consumer Harm Regulation B/Regulation V/HMDA 18%
Inadequate Risk Monitoring Practices & Compliance Testing/Audit 6%