The FDIC issued a new publication earlier this month providing a high-level overview of consumer compliance issues identified during 2018. In particular, the issues addressed in this publication relate to the FDIC’s supervision of state non-member banks that are not members of the Federal Reserve System.
The FDIC highlights five areas where the most noticeable issues were identified:
- Overdraft Programs
- Violations of Section 8 of RESPA
- Mistakes in the investigation and EFT error resolution process as defined by Regulation E
- Improper disclosures associated with Skip-A-Payment Loan programs
- Inaccurate disclosure of APR and/or finance charges related to line of credit periodic statements
In addition, the publication provides the five most frequently cites statutes/regulations which represent 62% of all Level 2 and 3 violations in 2018.