Recent Regulatory Actions in Banking Industry

Explore recent regulatory actions in the banking industry, covering topics such as fair lending settlements, UDAAP violations, credit card issues, student loan practices, and foreclosure settlements involving major banks like Bank of America, Wells Fargo, and Ally Financial. Stay informed about compliance challenges and penalties faced by financial institutions.

• Banking industry
• Regulatory actions
• Compliance
• Fair lending
• UDAAP

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1. Washington Bankers Association Executive Development Program Audit and Compliance Recent Regulatory Actions Presenter: David McCrea U.S. Program Manager Global Regulatory Compliance Team Infosys Limited

2. Fair Lending Settle accusations of discrimination against Hispanic/Latino and Black/African American customers Ally Bank December 2013 Indirect Auto Lending $18 million CMP $80 million restitution Wells Fargo July 2012 $175 million Bank of America/Countrywide December 2011 $335 million SunTrust June 2012 $21 million

3. UDAAP Duty to protect you customers and your customers customers Wachovia April 2008 Processed 3rd Party transactions Did not act upon complaints lodged against their customer by their customers customers

4. UDAAP Unfair Billing and Deceptive Marketing American Express Bank December 2013 Customer unfairly billed for identity theft protection products Deceptive marketing practices relating to debt cancellation product $3 million CMP from OCC $2 million CMP from CFPB $4.5 million restitution

5. UDAAP Credit Cards Capital One July 2012 $35 million CMP and $150 million restitution Debt collection and cancellation products and lack of risk management program to identity UDAAP American Express Centurian June 2009 $3 million restitution Sent convenience checks then lowered credit limits such that checks bounced Providian June 2000 At least $300 million in restitution Inadequate disclosure of limitations on credit insurance product, promised lower rates did not materialize, No Annual Fee but credit protection required, inadequate disclosure of requirements to earn incentive for transferred balance

6. UDAAP Student Loans Cole Taylor Bank July 2014 Deceptive practices by Higher One, under Cole Taylor's oversight, that misled students about the OneAccount CMP of $3.51 Million Corrective Action Restitution

7. Foreclosures April 2012 $26 billion settlement Bank of America Citibank JPMorgan Chase Wells Fargo Ally Financial Independent Review

8. U.S. Sanctions Laws June 2014 BNP Paribas Parent of Bank of the West Federal Reserve penalty of $508 million Assessments by all agencies involved - $8.9736 Billion Omission or concealment of relevant information in payment messages sent through BNP Paribas's New York branch Requires creation of an OFAC compliance office

9. Flood Insurance FDIC First State Bank of Decatur, Decatur, Michigan (Dated 05-29-14) $6,200 Bancroft State Bank, Bancroft, Wisconsin (Dated 03-06-14) $15,065 Citizens State Bank, Lena, Illinois (Dated 02-19-14) $5,470 Pilot Grove Savings Bank, Pilot Grove, Iowa (Dated 02-24-14) $3,960 Upper Peninsula State Bank, Escanaba, Michigan (Dated 02-27-14) $2,000 BankOrion, Orion, Illinois (Dated 01-30-14) $11,285 Fremont Bank, Fremont, California (Dated 01-29-14) $13,320 OCC The Somerville National Bank Somerville, Ohio (Dated 05-29-13) $8,770 Equitable Bank Grand Island, Nebraska (Dated 05-27-13) $6,115 FNB Bank, N.A. Danville, Pennsylvania (Dated 09-18-13) $43,120 Great Plains National Bank, Elk City, Oklahoma (Dated 12-03-13) $11,925 National Bank of Ohio, Oak Harbor, Ohio (Dated 12-19-13) $18,160 Mutual of Omaha Bank, Omaha, Nebraska (Dated 12-12-13) $51,765 First Federal Bank. Harrison, Arkansas (Dated 12-10-13) $3,000 Federal Reserve Board First Southern Bank, Boca Raton, Florida (Dated 06-12-14) $4,000 Western Bank, Lordsburg, New Mexico (Dated 05-16-14) $5,410 Bank of Gueydan, Gueydan, Louisiana (Dated 05-09-14) $10,545 Uinta Bank, Mountain View, Wyoming (Dated 04-10-14) $9,985 Transpecos Banks, Pecos, Texas (Dated 01-06-14) $2,710 Tioga State Bank, Spencer, New York (Dated 01-06-14) $4,180

10. Bank Secrecy Act TD Bank HSBC ING Barclays September 2013 Failure to file SARs $37.5 million penalty $600 million restitution July 2012 Chief Compliance Officer stepping down Lax controls Laundering Mexican drug cartel money June 2012 $619 million penalty June 2012 $453 million settlement UK and US

11. Bank Secrecy Act JP Morgan Chase January 2014 Deficiencies in the BSA/AML compliance program, customer due diligence, internal controls, and testing OCC - $350 million CMP US Attorney - $1.7 billion forfeiture FinCEN - $461 million CMP

12. Servicemembers Civil Relief Act Capital One July 2012 Quarterly reports from the Audit and Risk Committee Develop SCRA program Develop SCRA audit program Written policies and procedures Review all foreclosures and credit cards including Kohl s cards 7/15/2006 present Remediation

13. Unsafe and Unsound Practices Credit Suisse May 2014 Inadequate risk-management and compliance program Violations of the federal income tax laws and various New York State laws FRB penalty of $100 million $2.6 Billion total penalties JP Morgan Chase September 2013 Unsafe and unsound practices related to derivatives trading activities conducted on behalf of the bank by the Chief Investment Office $300 million CMP

14. Next Big Topic Debt Collection Practices

15. Other Actions Bank closures Bank mergers MOUs C & Ds CMPs Removal and Prohibition Orders