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Comp Blog

New - July 1: HELOC Guidance / Integrated Disclosure Recording / Consumer Compliance Outlook / OFAC Violation

By: Danielle Wright

CommentTuesday - July 1, 2014

Guidance for home equity lines of credit nearing their end-of-draw periods

The Board of Governors of the Federal Reserve System (FRB), the Federal Deposit Insurance Corporation (FDIC), the National Credit Union Administration (NCUA), and the Office of the Comptroller of the Currency (OCC) and the Conference of State Bank Supervisors (CSBS) today issued guidance to financial institutions regarding home equity lines of credit (HELOCs) nearing their "end-of-draw" periods, which occurs when the principal amount of the HELOC must begin to be repaid. The guidance describes how financial institutions can effectively manage their potential exposures under these circumstances. The guidance promotes an understanding of potential exposures and describes consistent, effective responses to HELOC borrowers unable to meet their contractual obligations. Also discussed are the appropriate accounting and reporting procedures for HELOCs nearing their end-of-draw periods.

Webinar now available on integrated disclosures

If you missed the June 17, 2014, FRB/CFPB Consumer Compliance Outlook Live webcast on the TILA-RESPA Integrated Disclosures Rule, a recording of the webinar is now available. Presentation materials from the webinar are also available. Those who have not previously registered for the event will need to provide registration information before accessing the recording.

Consumer Compliance Outlook

The Second Quarter 2014 issue of Consumer Compliance Outlook is now available.  Consumer Compliance Outlook is a Federal Reserve System publication dedicated to consumer compliance issues.  Items covered in the issue include a CFPB update; recent court opinions (TILA, EFTA, FCRA, NFIA); and an article on social media and compliance risks.

OFAC’s largest ever settlement

The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced a $963 million agreement, the largest settlement to date, with BNP Paribas SA (BNPP) to settle its potential liability for apparent violations of U.S. sanctions regulations.   The specific payment practices used to process sanctions-related payments included omitting references to sanctioned parties; replacing the names of sanctioned parties with BNPP’s name or a code word; and structuring payments in a manner that did not identify the involvement of sanctioned parties in payments sent to U.S. financial institutions.






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