A Regulatory & Legislative Advisory for Compliance Professionals
Inside . . .
2 Card Issuers Should
Make Credit Scores
2 Prepaid Card Fee
3 ABA: Prioritize Debt
Bank Secrecy Act
5 New Sanctions re
5 FinCEN: Institutions
6 OCC: BSA Risk
6 Treasury Focuses
on Virtual Currency
7 Guidance to FX
7 Call for National
REGULATORY FEEDBACK INITIATIVE
With the onslaught of new regulatory requirements and the knowledge of more to
come, one of the top concerns among bank and thrifts is inconsistent supervisory
expectations during agency examinations and visitations. Rather than coping with
these inconsistencies and the uncertainty regarding what issues will be covered in an
examination or how a regulation will be enforced, as well as wondering whether the
bank down the street has a similar exam experience, bankers can take action with
Regulatory Feedback Initiative.
The Initiative is a confidential electronic survey which allows bankers to anonymously
provide details on their most recent safety and soundness or compliance examination.
Over 2,000 survey results have already been aggregated and analyzed to identify
discrepancies in how banking regulations are enforced, and to help avoid inconsistent
regulatory treatment. Bankers completing a survey can request aggregate reports. The
success of the Regulatory Feedback Initiative depends on banks integrating the
survey into their ongoing regulatory compliance monitoring and completing a survey
immediately after each regulatory exam or visitation. Importantly, please submit
only one survey per bank.
One of the primary benefits of the Initiative is the ability to identify discrepancies in
“real time.” Bankers have a unique opportunity to improve the industry’s regulatory
climate and truly hold examiners accountable, by making their voices heard after each
exam. It doesn’t matter when your last exam was, if you haven’t already filled out a
Post Exam Survey from the Coalition of Bankers Associations, please take a minute
right now and plan to do it by April 30, 2014. To find out more information about the
Regulatory Feedback Initiative and to complete the survey, click here.
ABA-BACKED FLOOD INSURANCE BILL SIGNED INTO LAW
President Obama on March 21 signed into law flood insurance affordability legislation
backed by ABA and its subsidiary, the ABA Insurance Association. The legislation
earlier passed both the House and Senate by large bipartisan majorities. In recent
months many homeowners, potential homeowners and lenders have become alarmed
over dramatic rate increases for coverage under the National Flood Insurance
Program as a result of reforms enacted as part of the Biggert-Waters Act of 2012.
Additional concerns have been raised over unintended consequences stemming from
new escrow requirements included in the reform bill.
ABA and ABIA worked extensively with Congress and a broad coalition of industry and
consumer groups to move legislation to address these unintended consequences in a