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OCC Compliance Policy and Office of the Ombudsman The NAACP Western Region I Civil Rights Advocacy Training Institute Economic Empowerment Breakfast Saturday, May 5, 2007

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2 Compliance Policy Division Organizational Structure Primary Function Secondary Function

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3 Primary Function Expert Advice to OCC Executive Management Examination Development and Guidance Examination Support Systemic Analysis of Key Issues

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4 Secondary Function Interagency Coordination Examiner Training and Development Industry Outreach External Representations

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5 Types of Examinations Community Reinvestment Act Fair Lending Consumer Lending Regulations Consumer Deposit Regulations Other Regulations

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6 Examination Outcomes Community Reinvestment Act Public Evaluations Reports of Examination Other Communication Methods Periodic Examination Follow-up

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7 Consumer Input Community Reinvestment Act – Comment Letters Corporate Application Process – Comment Letters Home Mortgage Disclosure Act – Review of Public Data

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8 Tools You Can Use www.occ.treas.gov www.ffiec.gov www.occ.treas.gov/customer.htm www.google.com

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9 Office of the Ombudsman

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10 Mission Statement The Ombudsman’s office is organized around core principles of dispute resolution and customer service. The office seeks to ensure that national banks and customers of national banks receive fair and expeditious resolution of their complaints through two distinct units within the office: Customer Assistance Group National Bank Appeals Process

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11 Office of the Ombudsman OMBUDSMAN National Banks Other Engaged Parties Customer-Focused OCC Public

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12 The OCC’s Office of the Ombudsman What We Do National Bank Appeals Process Customer Assistance Group How the OCC Uses Consumer Complaints Supervisory Process Guidance to the Industry Enforcement Authority Top Issues for Consumers Credit Cards Checking Accounts Home Mortgages

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13 CAG Technology Quality Assurance Program

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14 Complaints Are An Opportunity Complaints can serve as an early warning system for potential problems. Rising complaint volume may be an indicator of risks: Compliance Strategic Transaction Reputation

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15 Case Processing Volumes

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16 Complaints by Major Product Type 2006 HELOCS & HELS (Home Equity Lines of Credit & Home Equity Loans) CCards (Credit Cards)

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17 *Fees and Charges Returned to Customers *Information based upon Complaint Closed Date

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18 Customer Assistance Group Assists customers of national banks and operating subsidiaries of national banks who have complaints related to applicable banking laws and regulations Provides informal consumer education on banking Facilitates communication between the bank and its customers

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19 OCC’s Office of the Ombudsman Mailing Address 1301 McKinney Street Suite 3450 Houston, TX 77010 Phone 800-613-6743 713-336-4300 713-336-4351 (fax) Internet www.occ.treas.gov E-mail customer.assistance@occ.treas.gov Samuel.Golden@occ.treas.gov or Craig.Stone@occ.treas.gov

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20 Questions from the Group

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21 Appendix

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22 Examples of Regulatory Guidance Issued in Response to Consumer Complaints Anti-Predatory Lending Guidance 12 CFR 34.3 Service Members Civil Relief Act AL 2004-8 Interagency Guidance on Overdraft Protection AL 2005-18 Credit Card Repricing and Promotional Rates AL 2004-10 Unauthorized Transfers (EFT) AL 2001-9 Guidance on Unfair or Deceptive Practices AL 2002-3 Credit Card Lending Account Management AL 2003-1 Secured Credit Card Lending Guidance AL 2004-4

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23 Staff Profile CAG is comprised of more than 70 compliance professionals including: 9 national bank examiners 15 certified regulatory compliance managers 1 certified risk professional 1 certified internal auditor 1 individual with a law degree Our staff is comprised of consumer compliance and bank operations professionals or individuals with previous experience in Bank Supervision. The majority of the staff join us from major bank Companies, such as JPM Chase, Bank of America, Citibank, American Express, Washington Mutual, Wachovia, and Wells Fargo.

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24 CAG Organizational Chart

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25 Complaint Life Cycle Initial Contact Phone, mail, fax or E-mail Receipt of Complaint Written with customer’s signature Document Scanning Unique case is created and documents are added. Review Bank Response * Case sent to CAG for resolution. Specialist reviews the response. Case could be closed at this point or sent back to the bank for additional information. Review w/ Supervision As needed or as part of the annual presentation to bank management Final Review Case Closing Specialist reviews any subsequent information provided by the bank and/or additional information from consumer. In cases involving technical legal interpretations, counsel and guidance are provided by OCC Chief Counsel’s Office. Initial Review Specialist reviews issue to ensure proper authorization, bank assignment, etc. Case is set to transfer to bank via CAGNet. Complaint Analysis Conducted by CAG Analyst, Team Manager, Supervisory staff *Are the bank’s actions consistent with applicable laws and regulations? *Was the customer treated fairly? *Bank customers who disagree with our findings may appeal to the Deputy Ombudsman.

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26 Selected Products with Significant Complaint Volume

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27 Distribution of Credit Card Complaints 2006 FDCPA (Fair Debt Collection Practices Act) FCRA (Fair Credit Reporting Act) ECOA (Equal Credit Opportunity Act)

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28 Distribution of Checking Account Complaints 2006 EFTA - Reg E (Electronic Fund Transfer Act and Regulation E) UCC (Uniform Commercial Code) FCRA (Fair Credit Reporting Act) FDCPA (Fair Debt Collection Practices Act) TISA - Reg DD (Truth in Savings Act - Regulation DD)

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29 Distribution of Mortgage Complaints 2006 RESPA (Real Estate Settlement Procedures Act) FDCPA (Fair Debt Collection Practices Net) FCRA (Fair Credit Reporting Act) ECOA (Equal Credit Opportunity Act) Customer Service 50%

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