Within a one-week period in January 2023, the Office of the Comptroller of the Currency (OCC) and the Consumer Financial Protection Bureau (CFPB) updated examination manuals on fair lending and mortgage servicing, respectively, signaling increased regulatory attention on risk management in these two important lending areas. These updates provide risk officers with the opportunity to reassess their risk management practices in these areas.
On January 12, 2023, the OCC revised the âFair Lendingâ booklet in the Comptrollerâs Handbook for the first time in over a decade. Revisions discuss current topics in fair lending, including:
Risk and compliance practitioners should review their institutionâs fair lending program for:
On January 17, 2023, the CFPB updated its mortgage servicing examination procedures, last revised in 2016.
The updates mainly address tools, such as streamlined loss mitigation options, available to mortgage servicers during the COVID-19 national emergency, and the continued use of some of the tools to help borrowers experiencing non-COVID hardship remain in their homes. The CFPB is referring to these options as âtemporary flexibilities.â
The updates also discuss areas of mortgage servicing that have been addressed in the CFPBâs âSupervisory Highlightsâ publication, which include:
Risk officers should review their institutionâs mortgage servicing risk assessment process to ensure that it addresses the impact and likelihood of borrower harm. Risk officers should also review prior issues of CFPB âSupervisory Highlightsâ and meet with first-line-of-defense managers to identify how they utilize the guidance to assess their mortgage servicing program. Additionally, risk management teams should review the institutionâs second-line-of-defense monitoring of servicing risks, including the following areas featured in recent issues of âSupervisory Highlightsâ:
The release of updated supervisory guidance is an opportunity for financial institutions to reassess their risk management programs in the areas of supervisory focus.
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