On 7/2/19, the FDIC announced updates to their Consumer Compliance Examination Manual (CEM) which examiners utilize when conducting compliance examinations. The manual contains exam procedures for consumer compliance regulations, the Community Reinvestment Act rules, and other supervisory requirements and helps to provide consistency among examiners when conducting examinations. Though this manual is specific to FDIC-regulated institutions, the information found within the manual can at least be considered “best practices” and thus beneficial to any financial institution.
The June 2019 udates to the Consumer Compliance Examination Manual include:
Consumer Compliance Examinations and Third Party Risk (II-1.1, 2.1, 3.1, and VII-4.1): Section was added and minor technical changes made to incorporate the Interagency Statement Clarifying the Role of Guidance.
Appeals (II-11.1): Updates were made to procedures for the review and processing of requests for review of material supervisory determinations to reflect amendments to the FDIC’s Guidelines for Appeals of Material Supervisory Determinations.
SOURCE Violation Codes (II-14.1): SOURCE violation codes were updated, added, or deactivated to reflect amendments to Regulations E related to the CFPB’s prepaid account rule and updates to the HMDA requirements.
Home Mortgage Disclosure Act (V-9.1): The HMDA chapter was updated to incorporate revised interagency HMDA examination procedures, HMDA data validation instructions for FDIC examination staff, and tables listing the Designated Key HMDA Data Fields.
Protecting Tenants at Foreclosure Act (V-16.1): New chapter includes procedures for assessing compliance with the Protecting Tenants at Foreclosure Act.
The FDIC Consumer Compliance Examination Manual can be found here.