Published March 11, 2014 | March 2014 issue
The article "The Roles of Relationship Managers and Consumer Affairs Contacts" references our Consumer Affairs hotline, a feature of Federal Reserve Bank consumer supervision mentioned in many Banking in the Ninth articles. In this article, we provide a few more details on this hotline.
The Consumer Affairs section within Supervision, Regulation, and Credit offers state member banks a dedicated telephone number to use for compliance questions and concerns. The hotline is monitored by Consumer Affairs staff daily. We provide a timely response to these questions, typically no later than a day.
The hotline report-and-respond process is as one would expect: Typically, a bank employee will leave a voice mail message briefly outlining his/her question. Examiners in the office assigned to monitor and respond to the questions review the message. Examiners then contact the bank to obtain additional information about the specific question or fact pattern.
Call volumes vary; however, we typically see an increase when new rules and regulations are issued. For example, we received many calls concerning the new mortgage rules in Regulations Z and X. Bankers asked for additional details surrounding documentation they must keep to support their assessment of a borrower’s ability to repay under the new regulation. We have also received questions about the small servicer exemptions, qualified mortgages, and rules for escrow accounts.
In addition to questions about new rules, examiners staffing the Consumer Affairs assistance hotline work with bankers on reviewing updated disclosures or questions about aspects of a bank’s compliance management program. Finally, we receive heavier call volume in February when compliance officers prepare HMDA data for the March 1 reporting deadline.
We use the information from these calls to reduce examination burden. In particular, the final information provided to the state member bank is documented and shared with the bank’s Consumer Affairs Contact and, if appropriate, the Safety and Soundness relationship manager. This process benefits the bank by ensuring examiners on site or involved in off-site monitoring of the bank are aware of the prior discussion and findings. As a result, they will not need to revisit the issue unless circumstances have changed.
In addition to documenting individual calls, examiners have recently begun compiling a database of questions. We will use trends in calls to offer training and education to bankers. This development fits with our approach to reduce later violations by equipping banks to comply with rules and regulations in advance. For example, some of the articles previously published in Banking in the Ninth aimed to answer the common questions we have received on the assistance line for a broad audience.
If you are a state member bank compliance officer and need our assistance, please feel free to call 612-204-6500 or 800-553-9656 and ask for the Consumer Affairs assistance hotline to be connected to the Consumer Affairs assistance voice mail.