q2 2024 COMPLIANCE UPDATES FOR FINANCIAL INSTITUTIONS By Troy Snyder, Brad Birkholz, Peyton Lydigsen, Andrea Pech and Shawn McGuffin Plante Moran, ICBC Silver Associate Member Our experts cover the top headlines each quarter to keep you apprised of regulatory compliance matters impacting community financial institutions. This quarter, we highlight several proposed rulemakings and other supervisory guidance to help navigate the current regulatory environment. ACCURACY PROBLEMS IN THE CREDIT REPORTING SYSTEM The Consumer Financial Protection Bureau (CFPB) issued an edition of Supervisory Highlights on April 8, 2024, that shared findings related to accuracy problems in the credit reporting system. The bureau found the following issues during recent examinations: • Consumer reporting companies failed to block or remove information related to identity theft and human trafficking. • Consumer reporting companies accepted information from unreliable furnishers. • Furnishers provided information to consumer reporting companies they knew was false. • Furnishers didn’t follow requirements to dispute investigations and identity theft. The consumer reporting companies and furnishers involved are taking corrective actions in response to the CFPB’s findings. ACTIONS TO COMBAT JUNK FEES CHARGED BY MORTGAGE SERVICERS The CFPB issued an edition of Supervisory Highlights on April 24, 2024, that shared recent examination findings regarding mortgage servicers. The bureau highlighted the following actions by mortgage servicers: • Charging illegal junk fees to consumers. • Sending deceptive notices to homeowners. • Violating loss mitigation rules that are designed to help struggling borrowers stay in their homes. • Missing deadlines to pay property tax and home insurance. The mortgage servicers involved are taking corrective actions, including changes to their policies and procedures. Refunds and remediations are being provided to homeowners for fee-related findings. THIRD-PARTY RISK MANAGEMENT PRACTICES The Federal Reserve System, Federal Deposit Insurance Corporation (FDIC) and Office of the Comptroller of the Currency (OCC) collectively issued the “Interagency Guidance on Third-Party Relationships: Risk Management” (TPRM Guidance) on May 3, 2024. This guide supports community banks in managing risks presented by third-party relationships. 20 | INDEPENDENT REPORT
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