Here are seven things that I think that I think. But I'm not completely sure yet...
- I think the days of lazy summers for compliance officers are over, if they ever existed. People like to hold on to myths, and I think this is one of them.
- I think we should all be nice to anyone responsible for mortgage compliance issues.
- I think we should impose a page limitation on proposed regulations. If you can't get it done in 200 pages, perhaps the document is a wee bit complicated for general consumption.
- I think that regulators expect a lot when they issue five rule-makings in one day. It is hard to comply with things when there isn't enough time in the day to read proposals, let alone analyze them.
- Now that I think about it, I think there should be an issue limit on top of the "page limit" for regulators. It is impossible for organizations to comply with scores of new laws, regulations and guidance documents when they are issued on top of each other. I wonder what our world would be like if each regulator was only allowed to issue five major rule-makings or guidance documents each year?
- I think regulators should point to existing guidance documents first whenever possible, rather than creating new documents. If existing guidance is adequate, enforce it.
- I think that's enough thinking for today.
Here are a few items of interest.
Regulation and the cost of credit. We warned folks that added layers of consumer protection and regulatory restrictions would drive up the cost of credit. It looks like we may be right. Your honor, I'd like to enter into evidence Exhibits One (CNN.com) and Two (WSJ.com).
OFAC. A bank has paid roughly $92,000 to settle claims of OFAC violations. The original fine was more than $200,000, but the bank self-reported the violation. I'm seeing an up-tick of OFAC violations. It is hard to know whether this is a general trend or whether the issues were specific to the affected financial institutions. In any event, it is something to track.
Reg Z. The Fed issued Consumer Affairs letter CA 10-10 to announce bank examiner procedures for the August 22, 2010 Reg Z changes.