Monthly Archives: July 2015

Bank Compliance Officers Draw on Outside Expertise

This week, the American Bankers Association released results of its bi-annual survey of Compliance Officers.  Key results show Compliance Officers managing external resources in critical areas, while banks are taking cautious approach to adding compliance risks. Nearly half of banks have outsourced at least one compliance obligation; of these, 76.9 percent outsourced the compliance audit [...]

July 27th, 2015|

IMF Warns Against Lack of Transparency and Beneficial Ownership

The International Monetary Fund (IMF) recently published a report focused on anti-money laundering efforts, as part of its Financial Sector Assessment Program for the United States. Per the program, the IMF conducts a regulatory review every five years across many U.S. financial sectors.  In this most recent report, the IMF concluded that the U.S., despite [...]

July 20th, 2015|

Q2 Results for Top Lenders Signal Strong Mortgage Market

Second quarter 2015 financial results for Wells Fargo and JPMorgan Chase signal a strong rebound in the mortgage market from 2014. This growth was attributed to healthy demand in the home purchase market, based on improving economic conditions, affordable home prices, and continued low interest rates (, 7/14/2015): “It was a strong quarter” for the purchase market, [...]

July 16th, 2015|

Senators Are Pushing the CFPB to Write Small Business Reporting Rule

On July 10, nineteen Democrat U.S. Senators sent a letter to the CFPB urging it to implement a rule required under the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank). The rule in question relates to Section of 1071 of Dodd-Frank, which requires the CFPB to collect and make public data on lending to small businesses. [...]

July 15th, 2015|

Mortgage Credit Stalls in June Despite Rising Prices and Low Rates

In May, home prices in ten states and the District of Columbia hit new peaks while interest rates remained below 4 percent. In general, the combination of these two factors are expected to fuel strong home purchasing activity. The rise in home prices is being attributed to low supply (CNBC, 7/7/2015): "A complementary rise in the [...]

July 14th, 2015|

CFPB Releases Data on 7,700 Complaints

The CFPB has expanded its publicly available complaints database with the addition of over 7,000 new complaints, including those made from mortgage applicants. An analysis of the newly available complaints highlights how many of the entries were received by larger institutions with nearly half coming from seven lenders (Mortgage Professional America, 6/29/2015): The CFPB released a snapshot [...]

July 9th, 2015|

Supreme Court to Address ECOA Spouse Rule

The Supreme Court agreed to settle the issue of whether spousal guarantors should be considered applicants and whether the Federal Reserve has the authority to create regulations to accomplish this under the Equal Credit Opportunity Act (ECOA). Since ECOA does not include guarantors in its definition of applicants, a split has arisen among circuits regarding the [...]

July 8th, 2015|

“Unreasonable” LTD Ratio Leads to a CRA Rating of NI for Miami-area Bank

The July 2015 release of CRA performance evaluations by the FDIC offers an example of how the loan-to-deposit (LTD) ratio test can over-shadow satisfactory performance in other tests under CRA. According to FDIC examiners, the LTD ratio for Intercontinental Bank of West Miami, FL did not meet expectations: The average net loan-to-deposit ratio of 21 percent is [...]

July 7th, 2015|

Black and Hispanic Applicants in NYC Were Twice as Likely to be Denied in 2013

According to an analysis of 2013 HMDA data, black and Hispanic applicants from New York City (NYC) were significantly more likely to be denied for a mortgage than white and Asian applicants (Morningstar, 6/19/2015): Black and Hispanic applicants are disproportionately denied conventional loans in New York City, with 33.6 percent and 29.2 percent of applications [...]

July 6th, 2015|

CFPB to Propose Consent Orders Against 3 Large Auto Lenders

Starting as early as July, the CFPB is poised to issue consent orders against three major lenders in automotive financing: American Honda Finance Corp.; Toyota Motor Credit Corp; and Nissan Motor Acceptance Corp. These consent orders will require payment to affected consumers and will represent a major victory in the CFPB's efforts to reduce pricing discretion [...]

July 3rd, 2015|