FDIC updates consumer exam compliance manual sections on appeals, HMDA exams, violation codes, more

Revised or new information regarding appeals of material supervisory determinations, Home Mortgage Disclosure Act (HMDA) exam procedures, SOURCE violation codes, and more are included in June 2019 updates to the manual that bank examiners use to conduct consumer compliance examinations, the Federal Deposit Insurance Corp. (FDIC) said Tuesday.

The agency’s Consumer Compliance Examination Manual (CEM) provides supervisory information to FDIC examination staff that conduct consumer compliance examinations, Community Reinvestment Act (CRA) performance evaluations, and other supervisory activities. It includes supervisory policies and examination procedures for evaluating financial institutions’ compliance with federal consumer protection laws and regulations.

The FDIC says the manual, designed to promote consistency and efficiency in the examination process and compliance with applicable laws and regulations, can be used by financial institutions to obtain more information about the agency’s examination process.

The agency’s June updates to the CEM include:

  • Consumer Compliance Examinations and Third Party Risk (II-1.1, 2.1, 3.1, and VII-4.1): Section was added and minor technical changes made to incorporate the Interagency Statement Clarifying the Role of Guidance.
  • Appeals (II-11.1): Updates were made to procedures for the review and processing of requests for review of material supervisory determinations to reflect amendments to the FDIC’s Guidelines for Appeals of Material Supervisory Determinations.
  • SOURCE Violation Codes (II-14.1): SOURCE (System of Uniform Reporting of Compliance and CRA Examinations) violation codes were updated, added, or deactivated to reflect amendments to Regulations E related to the CFPB’s prepaid account rule and updates to the HMDA requirements.
  • Home Mortgage Disclosure Act (V-9.1): The HMDA chapter was updated to incorporate revised interagency HMDA examination procedures, HMDA data validation instructions for FDIC examination staff, and tables listing the Designated Key HMDA Data Fields.
  • Protecting Tenants at Foreclosure Act (V-16.1): New chapter includes procedures for assessing compliance with the Protecting Tenants at Foreclosure Act.

FDIC Consumer Compliance Examination Manual