Monthly Telephone Briefing

BCG offers its members monthly Telephone Briefings on legal and regulatory matters. Also, you have the option to listen to audio presentations of meetings archived for up to 12 months after their original presentation dates. This benefit is called, “Listen While You Work.” You simply select a topic, minimize the screen, and listen to a streaming audio presentation while you work at your desk.

Please feel free to sign up annually, register for the next scheduled BCG Monthly Telephone Briefing or download an archived Handout below.

Current BCG Monthly Telephone Briefing Topic(s)

Friday, February 21, 2020
12:00 - 1:30 p.m.

Reporting Accurate Information to the Credit Bureaus

The CFPB and the banking regulators continue to express concern about the accuracy of information which financial institutions report to credit bureaus, what is technically known as the furnishing of information to consumer reporting agencies. In December 2019 the CFPB devoted four pages of its quarterly “Supervisory Highlights” to the specific subject of errors and other problems it found in examinations of furnishers of information. Some of the discrepancies noted involved furnishing of information that was actually incorrect, both as to loans and as to deposit accounts (overdrafts), while others involved the failure to have adequate written policies and procedures in place.

During the Monthly Telephone Briefing on February 21 we will discuss the applicable regulations and regulatory guidelines on the furnishing of accurate information to consumer reporting agencies. We will also provide practical guidance for the drafting of compliant policies and procedures on the subject. And we will have plenty of time for questions. Handout to be posted Thursday, February 20th.

OCC & FDIC Proposal to Revise CRA Regulations

As bankers are well aware, the OCC and the FDIC issued a proposed rule in December 2019, without the Federal Reserve’s concurrence, which would amend the CRA regulations in an effort to modernize the regulations and bring more transparency and consistency to the CRA examination process. 85 FR 1204 (January 9, 2020). The proposed rule is aimed at clarifying which activities qualify for CRA credit (which would include publishing a list of qualifying activities), creating a more transparent and objective method for measuring CRA performance (including establishing certain performance benchmarks), and providing for more transparent, consistent and timely CRA-related data collection, recordkeeping and reporting.

Please join us for the February Telephone Briefing when we will discuss how these two agencies would bring CRA into the digital age. We will review the major points of the proposal, including the agencies’ plans to (i) expand what would be considered an assessment area beyond just a bank’s physical branches, (ii) reduce the delays in the agencies’ issuance of performance evaluations and making PEs more useful, comparable across banks, and meaningful for stakeholders, and (iii) increase the loan size threshold and the revenue size threshold for small business and small farm loans. Handout to be posted Thursday, February 20th.