On August 8, 2022 in the Federal Register (and a correction on August 12) the FDIC reported they had renamed the Consumer Response Center to the “National Center for Consumer and Depositor Assistance”.
This Division is referenced in the Fair Housing regulation at 12 CFR 338 and in the Consumer Protection in Sales of Insurance at 12 CFR 343.
How does this impact your institution? Well, if are OCC or FRB regulated, it doesn’t. This affects the Equal Housing Lender (EHL) poster for FDIC regulated institutions. The renamed division is referenced in two places on that poster.
Old Poster Language:
Federal Deposit Insurance Corporation, Consumer Response Center, [Insert address for the Consumer Response Center stated on the FDIC’s website at www.fdic.gov]
New Poster Language:
Federal Deposit Insurance Corporation, National Center for Consumer and Depositor Assistance, https://ask.fdic.gov/fdicinformationandsupportcenter.
As you can see, the updated Regulation added a website reference to the EHL poster: https://ask.fdic.gov/fdicinformationandsupportcenter. There was no website referenced on the EHL poster in the regulation previously.
The update to the Fair Housing regulation also removed the street address from the poster. We have been advised by the FDIC the street address did not change, but an explanation why the address was removed from the signage was not provided. Perhaps the FDIC believes everyone inside a bank branch has electronic access.
So, do we need to change the signage now? We would advise at the very least if new EHL signs are ordered, or if the Bank creates their own signs, they have the updated information and keep the street address, if possible. If the Bank doesn’t want to order new signage, blank labels are available at most office supply companies so you can update the signage yourself.
The Consumer Protection in Sales of Insurance contains the information in Appendix A which describes the grievance process for insurance sales. If an institution includes the information on any disclosures or (and this is not required) publishes the grievance process for insurance sales, be sure to update the name and website from Appendix A of 12 CFR 343.
If you are one of the “quick to put things together people” you’ve also realized the ECOA notice on Regulation B Adverse Actions uses the same Division information. On March 17, 2023 the CFPB released a Final Rule (published March 20) which among other non-substantive changes, corrects and updates CFPB and other Federal agency contact information found at certain locations in Regulations B, E, F, J, V, X, Z, and DD. In addition to the recent FDIC name change, it also codified a name change for the OCC and NCUA.
The rule is effective April 19, 2023, however, the mandatory compliance date for the amendments to Regulations B, J and V is March 20, 2024.
Prior to the mandatory implementation date shown above, your Adverse Action addresses should read:
- CFPB: Bureau of Consumer Financial Protection, 1700 G Street NW, Washington, DC 20552
- OCC: Office of the Comptroller of the Currency, Customer Assistance Group, P.O. Box 53570, Houston, TX 77052
- FDIC: Division of Depositor and Consumer Protection, National Center for Consumer and Depositor Assistance, Federal Deposit Insurance Corporation, 1100 Walnut Street, Box #11, Kansas City, MO 64106
- FRB: Federal Reserve Consumer Help Center, P.O. Box 1200, Minneapolis, MN 55480
- NCUA: National Credit Union Administration, Office of Consumer Financial Protection, 1775 Duke Street, Alexandria, VA 22314
Remember TCA is A Better Way to comply and get updated on regulatory changes. Contact us at [email protected] or (800) 934-7347.