Increased Actions and Renewed Focus on TILA
Q3 2016 HighlightsThe frequency of regulatory enforcement action increased from Q2 2016 to Q3 2016 by a relatively high 17%, as seen in Figure 1, but remains lower than rates observed in other prior periods reviewed in this issue. Approximately two-thirds of enforcement actions were issued by the four major agencies, with fourteen from the CFPB, thirteen from the FDIC, six from the OCC, and five from the FRB (see Figure 2). The CFPB’s actions centered around unfair, deceptive, or otherwise improper lending practices in violation of UDAAP, TILA, and FCRA, while the FDIC, the OCC, and the FED issued actions for violations of rules and regulations including BSA/AML, compliance with capital adequacy requirements, the Servicemembers Civil Relief Act, and the National Flood Insurance Program. UDAAP- and BSA/AML-related violations accounted for the highest numbers of actions in Q3 2016. More importantly, there appears to be a renewed focus placed on TILA compliance, as evidenced by a dramatic increase in related actions in the current quarter (seven actions) from previous periods under review (versus no more than two actions in any one period).
Read the full article for additional commentary on Q3 2016 financial enforcement action, and related charts and graphs.