FDIC’s consumer compliance exam manual updated with seven key changes

The Consumer Compliance Examination Manual (CEM) of the federal insurer of bank deposits has been updated in at least seven areas, the agency said Thursday.

Among the key areas the Federal Deposit Insurance Corp. (FDIC) listed in a release as updated are:

  • Pre-Examination Planning (Section II, part 4.1): To reflect revised examination planning procedures and to conform to the revised examination risk scoping document, known as the Assessment of Risk of Consumer Harm (ARCH).
  • Review and Analysis (II-5.1): To conform to the revised ARCH and to reflect current applicable regulations.
  • Documenting the Examination (II-7.1): To conform to the revised ARCH and to remove an outdated workpaper requirement.
  • Examination and Visitation Frequency (II-12.1): To clarify that the FDIC will perform introductory meetings with de novos and charter conversions that are newly under FDIC supervision.
  • SOURCE Violation Codes (II-14.1): For the Fair Housing Act (2 codes revised) and the Telephone Consumer Protection Act (2 codes added; 3 duplicative codes removed; 4 codes revised).
  • Pre-Examination Information Packet (III-1.1): To reflect the content of the letter sent to institutions about a scheduled compliance or compliance and CRA examination.
  • Gramm-Leach-Bliley Act (VIII-1.1): To incorporate the current Examination Checklist.

April 2021 updated FDIC Consumer Compliance Examination Manual