Lenders operating across multiple metro areas, in ADI’s experience, provide their branches with national rate sheets through which they price first-lien mortgages. Despite the single rate sheet, the lender’s many branch managers confront different competitive environments and are often tasked with refining rate sheet-based pricing to meet local conditions and maximize loan originations. Branch Manager [...]
On September 28, 2017, the Federal Financial Institutions Examination Council (FFIEC) announced the availability of 2016 mortgage lending data submitted in compliance with the Home Mortgage Disclosure Act (HMDA). This database of mortgage activity is relied upon by regulators, examiners, academics, industry leaders, and members of the general public to analyze the performance of mortgage lenders with regard [...]
Can a city, or potentially other governmental entities, sue lenders over their discriminatory lending practices under the Fair Housing Act? On May 1, 2017, the U.S. Supreme Court said “yes,” but with the following conditions: The city must be an “aggrieved person” within the meaning of the Fair Housing Act; The alleged harm must be [...]
Federal anti-money laundering (AML) regulations, rooted in the Bank Secrecy Act (BSA) and USA PATRIOT Act, have long required financial institutions to maintain internal control systems to assure compliance, provide for independent testing, designate individuals responsible for compliance and provide training for all appropriate personnel. Moving beyond this federal BSA/AML framework, the New York State [...]
On June 29, 2016, a new case was added to the growing list of evidence signaling the importance of redlining as a key area of focus for Fair Lending compliance. In a joint effort between the Consumer Finance Protection Bureau (CFPB) and the U.S. Department of Justice (DOJ), BancorpSouth was accused of several discriminatory practices related [...]
In this contribution to ADI Adviser, ADI Senior Economist Paul J. Strasberg discusses how integrating modeling results can enhance the selection of comparators for a comparative file review (CFR) in a Fair Lending analysis of underwriting. Paul demonstrates how the use of propensity score matching (PSM) "effectively removes the judgments that a lender’s compliance analyst might make when [...]
In recent years, the Department of Justice (DOJ) and various federal, state, local and non-profit entities have generated many headlines about identifying and pursuing cases of redlining against financial institutions. Recent cases include: a $33 million settlement between Hudson City Savings Bank and the DOJ; an $825,000 settlement between Evans Bank and the Attorney General [...]
Anti-money laundering regulations require financial institutions to prevent their customers from conducting illegal business activities through their services. AML transaction monitoring software uses artificial intelligence to sift through thousands of transactions to identify deviations from usual and customary activity, as defined by the rules and parameters programmed into the software. Not all alerts indicate wrongdoing, [...]
For financial institutions, managing bank fraud and identify theft is a 24/7 challenge. The American Banker recently highlighted the growing problem of telephone fraud at bank call centers – employees being conned into giving up critical customer information to criminals or changing account passwords. Although the article focuses on call centers, the risk is also [...]
On Oct. 15, 2015, the Consumer Financial Protection Bureau (CFPB) issued its long-awaited final rule amending and expanding the mortgage loan application data reporting requirements under Regulation C and the Home Mortgage Disclosure Act (HMDA). It is critical for lenders who are subject to the final rule to begin compliance preparations now, before it goes [...]
