Consumer Compliance

Sections in this Topic

Consumer Compliance Risk Management Program
New Products and Services
Fair Lending Compliance
CRA Performance Evaluation
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Consumer Compliance Risk Management Program

As the bank grows in asset size, adds new products and services, and the business strategy becomes more complex, ensure that all elements of the consumer compliance risk management program develop accordingly. Increased complexity requires a more robust and formal program to ensure ongoing compliance with consumer laws and regulations. While portions of the program may be outsourced, overall responsibility for compliance remains with senior management and the board of directors.

New Products and Services

All documentation associated with new products or services should be reviewed for compliance with consumer laws and regulations prior to implementation. In addition, the board and senior management should also be aware of any additional operational, legal, or reputational risks associated with new products and, if necessary, take appropriate action to mitigate such risks.

Fair Lending Compliance

As the variety and complexity of credit offerings increase, an institution may find it advantageous to conduct self-tests or self-evaluations to measure or monitor compliance with the Equal Credit Opportunity Act (ECOA) implemented by Regulation B. In addition to mitigating risk, conducting reviews in accordance with the Interagency Fair Lending Examination procedures may qualify the bank for a streamlined examination process.

CRA Performance Evaluation

CRA regulations specify different examination procedures for banks based on their asset size. A bank should monitor its transition from a small bank (as of 1/1/13, less than $296 billion in assets) to an intermediate small bank ($296 million up to $1.186 billion), or from an intermediate small bank to a large bank ($1.186 billion or more in assets), because the institution’s performance under the regulatory assessment criteria differs as a result of its asset size. Also, as the institution expands its geographic footprint, the institution should monitor its assessment area compliance.