On October 11, 2011, the Office of the Comptroller of the Currency (OCC) issued Bulletin 2011-41 advising their institutions on the names and addresses to be disclosed on various notices and/or posters required by various regulations. These include the Community Reinvestment Act (CRA), Equal Credit Opportunity Act (ECOA) and the Fair Housing Act (FHA). These changes are a result of the July 21st transfer of the Office of Thrift Supervision (OTS) functions to the OCC and are required to be made within 90 days.
CRA PUBLIC NOTICE
|Large Bank Supervision Deputy Comptroller Large Bank Supervision Office of the Comptroller of the Currency 250 E Street, SW Washington, DC 20219-0001||Midsize & Credit Card Bank Supervision Deputy Comptroller Midsize Bank Supervision Office of the Comptroller of the Currency 250 E Street, SW Washington, DC 20219-0001|
|Central District Deputy Comptroller Central District Office of the Comptroller of the Currency One Financial Place Suite 2700 440 South LaSalle Street Chicago, IL 60605||Northeastern District Deputy Comptroller Northeastern District Office of the Comptroller of the Currency 340 Madison Avenue Fifth Floor New York, NY 10173-0002|
|Southern District Deputy Comptroller Southern District Office of the Comptroller of the Currency 500 North Akard Street Suite 1600 Dallas, TX 75201||Western District Deputy Comptroller Western District Office of the Comptroller of the Currency 1225 17th Street Suite 300 Denver, CO 80202|
FAIR HOUSING POSTEROffice of the Comptroller of the Currency Customer Assistance Group 1301 McKinney Street, Suite 3450 Houston, TX 77010-9050
The provision dealing with submission of FHA complaints to HUD remains unchanged.
The enforcement authority of ECOA for OCC-supervised institutions with assets greater than $10 billion was transferred to the Consumer Financial Protection Bureau (CFPB) by the Dodd-Frank Act. The CFPB plans to update ECOA to reflect the supervisory changes; however until this occurs, financial institutions should continue to provide the address as specified in Appendix A of the regulation.
Federal savings associations which are now supervised by the OCC should continue to use the OTS address for complaints. ECOA and other consumer complaints that are received OTS address will be forwarded to the appropriate supervisory agency for processing. Similarly, complaints received by the OCC for institutions supervised for consumer compliance by the CFPB will be forwarded to the CFPB.
Deb joined Banker’s Compliance Consulting with twenty years of experience in the banking industry. Her past positions include teller, credit review analyst, assistant financial officer, BSA Officer, Compliance Officer, and Director of Compliance. She has worked for both a small community bank and a large billion-dollar bank.
Deb has Associate Degrees in Business Management and Accounting. She is a graduate of the American Bankers Association National Graduate School of Compliance Management, an honors graduate of Schools of Banking Compliance School, and a graduate of Schools of Banking Advanced School of Banking. Deb’s considerable knowledge and experience make her a valuable member of the Banker’s Compliance Consulting Team. Deb is a Certified Regulatory Compliance Manager (CRCM) and a Certified Anti Money-Laundering Specialist (CAMS).
Deb loves to spend her free time cycling, running, kayaking and weight lifting with her husband. Between them, they have three adult children and six grandchildren. Other interests include anything outdoors and anything she hasn’t done or seen yet!