Annual Report 2002 - ffiec

ACTIVITIES OF THE INTERAGENCY STAFF TASK FORCES
Task Force on
Consumer Compliance
The Task Force on Consumer Compliance
promotes policy coordination
and uniform enforcement of
consumer protection laws and regulations.
The task force, composed of
senior personnel from each of the
five agencies represented on the
Council, identifies and analyzes
emerging consumer compliance
issues and develops proposed policies
and procedures to foster consistency
among the agencies. Additionally,
the task force addresses
legislation, regulations, and policies
at the state and federal level that
may have a direct or indirect bearing
on the compliance responsibilities
of the five agencies.
During 2002, the task force had
three standing subcommittees to
help promote its mission: Community
Reinvestment Act, Electronic
Banking, and Home Mortgage
Disclosure Act (HMDA). Ad hoc
working groups are also created to
handle particular projects and
assignments. The task force meets
monthly to address and resolve
common issues in compliance
supervision. Significant issues are
referred to the Council for action.
However, the Council has delegated
to the task force the authority to
make certain decisions, such as
approve examination procedures.
Initiatives Addressed in 2002
Examination Procedures on Real Estate
Settlement Procedures Act (RESPA)
compliance: The mortgage reform
working group reviews and analyzes
mortgage-related issues. On
January 14, 2002, and August 8,
2002, the task force approved and
issued guidance for agency examiners
in response to the effect of court
decisions in the Seventh and Fourth
Circuits on lender fees under
RESPA.
Examination Procedures for the Home
Ownership and Equity Protection Act:
The mortgage reform working
group updated existing Truth in
Lending examination procedures
and associated work documents to
incorporate the revised requirements
on whether certain loans are
considered to be high-cost mortgage
loans.
Examination Procedures for Rule on
Prohibition Against Using Interstate
Branches Primarily for Deposit Production:
The amended rule implements
section 106 of the Gramm-Leach-
Bliley Act of 1999, which amends
section 109 of the Riegle-Neal Interstate
Banking and Branching Efficiency
Act of 1994. The working
group on deposit-production offices
revised the existing examination
procedures to incorporate the regulatory
revisions.
Consumer Leasing Examination Procedures:
The task force revised the
Task Force on Consumer Compliance meeting.
existing consumer leasing examination
procedures to incorporate
amendments to the official staff
commentary on Regulation M.
HMDA Efficiency: At the Council’s
direction, the task force convened a
working group to identify possible
changes to the HMDA data collection
process that would result in
cost savings. The working group
identified three areas in which efficiencies
could be realized.
First, the working group identified
changes in the data storage process
that would result in cost savings to
the agencies. Second, potential cost
savings could be realized from
reviewing the HMDA aggregate
tables to ensure they continue to be
useful. Third, the continued migration
of HMDA products from CD-
ROM to web-based applications
would provide additional cost
savings. The task force, with the
approval of the Council, agreed to
proceed with implementing these
aforementioned cost-savings
initiatives.
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