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
|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
|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%|