A Regulatory & Legislative Advisory for Compliance Professionals
Inside . . .
DAVID DICKINSON AWARDED
2016 DISTINGUISHED SERVICE AWARD
2 Report on Auto Title
3 Guidance on
At the ABA Regulatory Compliance Conference on June 12, the ABA Compliance
Administrative Committee awarded the 2016 Distinguished Service Award to David
Dickinson, CRCM, president of Banker's Compliance Consulting. Dickinson began his
compliance career with FDIC as an examiner and later became a loan officer for a
community bank. The award recognizes outstanding leadership, initiative and
accomplishment in banking regulatory compliance management.
3 ABA Challenges
FCC on Debt
"David is recognized throughout the industry for his passion and commitment to the
compliance community," said John Topczewski, chairman of ABA's Compliance
Administrative Committee. "He goes above and beyond to educate his fellow
compliance professionals on complex issues, and we are fortunate to have him as a
friend, teacher and industry advocate." Topczewski is also senior vice president and
chief compliance officer of Johnson Bank in Wisconsin.
4 Comment on
CFPB PROPOSAL COULD CRIPPLE
INNOVATION IN SMALL-DOLLAR CREDIT
5 Changes to RHS
Home Loan Program
The Consumer Financial Protection Bureau on June 2 released a proposed rule that
would sharply curtail short-term, small-dollar consumer loans. The proposal would
define certain small-dollar loans as “abusive and unfair” if lenders fail to reasonably
determine borrowers’ ability to repay the loan or satisfy an exception. Comments on
the proposal are due by September 14.
Bank Secrecy Act
While principally targeted at payday and auto title loans, the rule would cover a wide
swath of short-term, small-dollar credit, including all loans with a term of 45 days or
less, as well as longer-term loans that have an all-in APR exceeding 36 percent and
that are repaid directly from a borrower’s account or secured by a car.
5 FinCEN Seeks
Support for Beneficial
6 Shasky Calvery
Testifies on Stopping
Virtually no banks currently offer deposit advances, the principal bank-based product
covered under the rule. But – according to a recent ABA survey – most banks make
small-dollar loans either as part of an established program or, more frequently, as an
accommodation to serve a customer upon request. Overdraft protection services
would be excluded from the rule.
6 Task Force
Financing in Latin
ABA expressed concern that the CFPB’s highly prescriptive proposal could impede
innovation by banks – as urged by other regulatory agencies – in small-dollar lending.
“While the Bureau has frequently expressed interest in expanding banks’ trusted role
in this market, the proposal fails to do so in a meaningful way and will significantly limit
the availability of small-dollar credit,” said ABA’s Virginia O’Neill.