OCC, Report

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Transcript of OCC, Report

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Appendix A

OCC Formal Enforcement Actions in the Consumer Protection Area 2009:

• Florida Capital Bank, N.A., Jacksonville, Florida (formal agreement – March 26, 2009). We required the bank to strengthen internal controls to improve compliance with applicable consumer laws and regulations.

• National Bank of Arkansas, North Little Rock, Arkansas (formal agreement –

March 30, 2009). We required the bank to strengthen internal controls to improve compliance with applicable consumer laws and regulations.

• Merchants Bank of California N.A., Carson, California (formal agreement –

March 31, 2009). We required the bank to strengthen internal controls to improve its information security program and to improve compliance with applicable consumer laws and regulations.

• Ozark Heritage Bank, N.A., Mountain View, Arkansas (operating agreement –

Apr. 10, 2009). We required the bank to adopt and ensure adherence to a written consumer compliance program.

• Farmers and Merchants National Bank of Hatton, Hatton, North Dakota (formal

agreement – May 11, 2009). We required the bank to strengthen internal controls to improve compliance with applicable consumer laws and regulations.

• Stone County National Bank, Crane, Missouri (formal agreement – June 25,

2009). We required the bank to strengthen internal controls to improve compliance with applicable consumer laws and regulations and to strengthen internal controls to improve its information security program.

• Union National Community Bank, Lancaster, Pennsylvania (formal agreement –

Aug. 27, 2009). We required the bank to strengthen internal controls to improve compliance with applicable consumer laws and regulations.

2008:

• Crown Bank N.A., Ocean City, New Jersey (consent order – Feb. 19, 2008). We required the bank to pay a civil money penalty of $7,500 for violations of HMDA and its implementing regulation.

• Wachovia Bank, N.A., Charlotte, North Carolina (consent order and formal

agreement – Apr. 24, 2008). In this FTC Act action, we required the bank to set aside $125 million for restitution to affected consumers and to develop policies

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and procedures governing its banking relationships with customers who regularly deposit remotely created checks. We also imposed a civil money penalty of $10 million and required the bank to $8.9 million to fund consumer education programs directed at the elderly.

• First National Bank USA, Boutte, Louisiana (formal agreement – May 21, 2008).

We required the bank to strengthen internal controls to improve compliance with applicable consumer laws and regulations.

• Home National Bank, Blackwell, Oklahoma (formal agreement – June 18, 2008).

We required the bank to strengthen internal controls to improve compliance with applicable laws and regulations.

• Granite Community Bank, N.A., Granite Bay, California (formal agreement –

July 21, 2008). We required the bank to strengthen internal controls to improve its information security program.

• Vineyard Bank, N.A., Corona, California (consent order – July 22, 2008). We

required the bank to strengthen internal controls to improve its information security program.

• Texas Republic Bank, N.A., Frisco, Texas (formal agreement – Aug. 14, 2008).

We required the bank to strengthen internal controls to improve its information security program and to improve compliance with applicable consumer laws and regulations.

• Beach First National Bank, Myrtle Beach, South Carolina (formal agreement –

Sept. 30, 2008). We required the bank to strengthen internal controls to improve its information security program.

• TomatoBank, N.A., Diamond Bar, California (consent order – Nov. 19, 2008).

We required the bank to strengthen internal controls to improve its information security program.

2007:

• Commerce Bank/Harrisburg N.A., Harrisburg, Pennsylvania (formal agreement – Jan. 29, 2007). We required the bank to strengthen its internal controls to improve compliance with applicable consumer laws and regulations.

• The Farmers National Bank of Osborne, Osborne, Kansas (formal agreement –

March 28, 2007). We required the bank to strengthen its internal controls to improve its information security program and compliance with all applicable consumer laws and regulations.

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• The First National Bank of Monahans, Monahans, Texas (formal agreement – Aug. 22, 2007). We required the bank to strengthen internal controls to improve compliance with applicable consumer laws and regulations.

• First National Bank of Lewellen, Lewellen, Nebraska (formal agreement – Oct.

27, 2007). We required the bank to strengthen internal controls to improve its information security program.

• First National Bank, Goodland, Kansas, Agreement (formal agreement – Dec. 13,

2007). We required the bank to strengthen its internal controls to improve compliance with applicable consumer laws and regulations.

2006:

• Alaska First Bank & Trust, N.A., Anchorage, Alaska (formal agreement – Feb. 2, 2006). We required the bank to strengthen its internal controls to improve compliance with applicable consumer laws and regulations.

• City First Bank of DC, N.A., Washington, DC (formal agreement – Feb. 6, 2006).

We required the bank to strengthen its internal controls to improve compliance with applicable consumer laws and regulations.

• Maryland Bank and Trust Company, N.A., Lexington Park, Maryland (formal

agreement – Feb. 10, 2006). We required the bank to strengthen its internal controls to improve compliance with applicable consumer laws and regulations.

• First National Bank, Fort Collins, Colorado (formal agreement – July 20, 2006).

We required the bank to strengthen its internal controls to improve compliance with applicable consumer laws and regulations.

• The First National Bank of Lindsay, Lindsay, Oklahoma (formal agreement – July

25, 2006). We required the bank to strengthen its internal controls to improve compliance with applicable consumer laws and regulations

• AB&T National Bank, Dotham, Alabama (formal agreement – July 27, 2006).

We required the bank to strengthen its internal controls to improve its information security program.

• Albany Bank and Trust, N.A., Albany, Georgia (formal agreement – July 27,

2006). We required the bank to strengthen its internal controls to improve its information security program

• Cornerstone Mortgage Co., Houston, Texas, an operating subsidiary of First

National Bank of Omaha, Omaha, Nebraska (consent order – Aug. 7, 2006). We required the company to pay a civil money penalty of $25,000 for violations of HMDA and its implementing regulation.

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• First National Bank of New Holland, New Holland, Ohio (consent order – Sept.

26, 2006). We required the bank to remedy violations of Regulation C, Home Mortgage Disclosure.

• First United Bank, N.A., Englewood, Colorado (consent order – Oct. 5, 2006).

We required the bank to strengthen its internal controls to improve compliance with applicable consumer laws and regulations.

• First National Bank, Julesburg, Colorado (formal agreement – Oct. 24, 2006).

We required the bank to strengthen its internal controls to improve compliance with applicable consumer laws and regulations.

2005:

• Peoples National Bank of Colorado, Colorado Springs, Colorado (formal agreement – Feb. 22, 2005). We required the bank to provide training for its employees on the Truth in Lending Act and the Real Estate Settlement Procedures Act and to strengthen its internal controls to improve compliance with applicable consumer laws and regulations.

• Chicago Title Insurance Company, acting as agent for Frost National Bank, San

Antonio, Texas; Southwest Bank of Texas, N.A., Houston, Texas; and Whitney National Bank, New Orleans, Louisiana (consent order – Feb. 24, 2005). We required the company to pay a civil money penalty of $5 million and to ensure the accuracy of real estate settlement documents provided to federally insured depository institution lenders and borrowers.

• The Fulton County National Bank and Trust Co., McConnellsburg, Pennsylvania

(consent order – March 23, 2005). We required the bank to employ a consultant to assess compliance with the Truth in Lending Act and the Real Estate Settlement Procedures Act and to provide information to the Assistant Deputy Comptroller regarding any violations requiring reimbursement.

• The First National Bank of Cainesville, Cainsville, Missouri (formal agreement –

May 23, 2005). We required the bank to strengthen its internal controls to improve compliance with applicable consumer laws and regulations and to improve its information security program.

• Amcore Bank, N.A., Rockford, Illinois (formal agreement – May 31, 2005). We

required the bank to strengthen its internal controls to improve compliance with applicable consumer laws and regulations.

• First Citizens Bank, N.A., Columbia Falls, Montana (formal agreement – June 9,

2005). We required the bank to strengthen its internal controls to improve

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compliance with applicable consumer laws and regulations and to improve its information security program.

• The Exchange National Bank of Cottonwood Falls, Cottonwood Falls, Kansas

(formal agreement – June 17, 2005). We required the bank to strengthen its internal controls to improve compliance with applicable consumer laws and regulations and to improve its information security program.

• First National Bank of Catlin, Catlin, Illinois (formal agreement –June 27,

2005). We required the bank to strengthen its internal controls to improve its information security program and compliance with applicable consumer laws and regulations.

• First Horizon Home Loan Corporation, a subsidiary of First Tennessee Bank

N.A., Memphis, Tennessee (consent order – June 30, 2005). We required the bank to pay a civil money penalty of $180,000 for violations of customer information security protections.

• First National Bank of Morgan, Morgan, Utah (formal agreement – July 15,

2005). We required the bank to strengthen its internal controls to improve compliance with applicable consumer laws and regulations.

• Big Lake National Bank, Okeechobee, Florida (formal agreement – Oct. 19,

2005). We required the bank to strengthen its internal controls to improve compliance with applicable consumer laws and regulations.

• The Laredo National Bank, Laredo, Texas, and its subsidiary, Homeowners Loan

Corporation (formal agreement – Nov. 1, 2005). We required the bank to set aside at least $14 million for restitution to affected customers and to strengthen internal controls to improve compliance with applicable consumer laws and regulations.

• The National Bank of Stamford, Stamford, New York (formal agreement – Nov.

15, 2005). We required the bank to strengthen its internal controls to improve its information security program.

• ABN AMRO Mortgage Group, Inc., a subsidiary of LaSalle Bank Midwest, N.A.

(consent order – Dec. 30, 2005). We required the bank’s subsidiary to provide $6.84 million in restitution and to pay a penalty of $6.25 million for falsely certifying compliance with the underwriting standards of the U.S. Department of Housing and Urban Development

2004:

• First National Bank of Southern Kansas, Mount Hope, Kansas (formal agreement – Jan. 29, 2004). We required the bank to strengthen internal controls to improve

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its information security program and to improve compliance with applicable consumer laws and regulations.

• First National Bank of Marin, Las Vegas, Nevada (consent order – May 24,

2004). In a second FTC Act action involving this bank, we required the bank to set aside at least $10 million for restitution to affected consumers and prohibited the bank from offering secured credit cards in which the security deposit is charged to the consumer’s credit card account.

• Merchants Bank of California N.A., Carson, California (consent order – May 27,

2004). We required the bank to strengthen internal controls to improve its information security program.

• First National Bank and Trust, London, Kentucky (formal agreement – June 11,

2004). We required the bank to strengthen its internal controls to improve compliance with applicable consumer laws and regulations.

• Surety Bank, N.A., Ft. Worth, Texas (consent order – June 22, 2004). We

required the bank to strengthen its internal controls to improve compliance with applicable consumer laws and regulations.

• Western National Bank, Lenexa, Kansas (formal agreement – June 24, 2004). We

required the bank to strengthen its internal controls to improve compliance with applicable consumer laws and regulations.

• The Fullerton National Bank, Fullerton, Nebraska (consent order – Sept. 21,

2004). We required the bank to provide external training for its compliance officer and to strengthen its internal controls to improve compliance with applicable consumer laws and regulations.

• First National Bank, Graford, Texas (formal agreement – Oct. 1, 2004). We

required the bank to strengthen its internal controls to improve compliance with applicable consumer laws and regulations.

• The Herring National Bank, Vernon, Texas (formal agreement – Oct. 25, 2004).

We required the bank to strengthen its internal controls to improve its data security program.

• The Upstate National Bank, Lisbon, New York (consent order – Nov. 4, 2004).

We required the bank to correct noncompliance with Community Reinvestment Act regulations and to strengthen its internal controls to improve compliance with applicable consumer laws and regulations.

• First National Bank of Paonia, Paonia, Colorado (consent order – Nov. 18, 2004).

We required the bank to strengthen internal controls to improve its information

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security program and to improve compliance with applicable consumer laws and regulations.

2003:

• First National Bank in Brookings, Brookings, South Dakota (consent order – Jan. 17, 2003). In this FTC Act action, we required the bank to set aside at least $6 million for restitution to affected consumers, to obtain prior OCC approval for marketing subprime credit cards to non-customers, to cease engaging in misleading and deceptive advertising, and to take other actions.

• Advance America, Cash Advance Centers, Inc. (consent order – Jan. 29, 2003).

We required the company to cease making payday loans through national banks.

• Peoples National Bank, Paris, Texas (consent order – Jan. 30, 2003). We required the bank to cease making payday loans and to pay a civil money penalty of $175,000.

• First National Bank of Northern Kentucky, Ft. Mitchell, Kentucky (consent order

– Feb. 11, 2003). We required the bank to strengthen its internal controls to improve compliance with applicable consumer laws and regulations.

• Household Bank (SB), National Association, Las Vegas, Nevada (formal

agreement – March 25, 2003). In this FTC Act action, we required the bank to provide restitution in connection with private label credit card lending and to make appropriate improvements in its compliance program.

• Industrial Bank, N.A., Oxon Hill, Maryland (formal agreement – Apr. 21, 2003).

We required the bank to strengthen its internal controls to improve compliance with applicable consumer laws and regulations.

• Guaranty National Bank, Tallahassee, Florida (consent order – May 2, 2003). We

required the bank to send proper adverse action notices to consumers who had been denied credit without receiving an adequate notice and to strengthen its internal controls to improve compliance with applicable consumer laws and regulations.

• Gateway National Bank, St. Louis, Missouri (formal agreement – June 20, 2003).

We required the bank to strengthen its internal controls to improve compliance with applicable consumer laws and regulations.

• The First National Bank of Deer River, Deer River, Minnesota (consent order –

June 23, 2003). We required the bank to strengthen its internal controls to improve compliance with applicable consumer laws and regulations.

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• The National Bank of the North East, North East, Pennsylvania (formal agreement – June 25, 2003). We required the bank to strengthen its internal controls to improve its information security program.

• First National Bank of Wiggins, Wiggins, Mississippi (consent order – July 9,

2003). We required the bank to strengthen its internal controls to improve compliance with applicable consumer laws and regulations.

• First Consumers National Bank, Beaverton, Oregon (formal agreement – July 31,

2003). In this FTC Act action, we required the bank to provide refunds of approximately $1.9 million to affected consumers in connection with credit card practices.

• Forrest City Bank, N.A., Forrest, Arkansas (formal agreement – Aug. 5, 2003).

We required the bank to strengthen its internal controls to improve compliance with applicable consumer laws and regulations.

• Clear Lake National Bank, San Antonio, Texas (consent order – Nov. 7, 2003).

In this FTC Act action, we required the bank to set aside at least $100,000 to provide restitution for borrowers who received tax lien loans, review a portfolio of mortgage loans to determine if similar violations existed, and take steps to prevent future violations.

• Dillard National Bank, Phoenix, Arizona (formal agreement – Nov. 13, 2003).

We required the bank to strengthen internal controls to improve its information security program.

• United Arizona Bank, N.A., Cave Creek, Arizona (formal agreement – Nov. 20,

2003). We required the bank to strengthen its internal controls to improve compliance with applicable consumer laws and regulations.

• First National Bank - Colorado, Fowler, Colorado (formal agreement – Dec. 18,

2003). We required the bank to strengthen its internal controls to improve compliance with applicable consumer laws and regulations.

2002:

• Fidelity National Bank, Medford, Wisconsin (formal agreement – March 26, 2002). We required the bank to strengthen internal controls to improve its information security program.

• First National Bank of Georgetown, Georgetown, Illinois (formal agreement –

Apr. 3, 2002). We required the bank to strengthen internal controls to improve its information security program.

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• North Cascades National Bank, Chelan, Washington (formal agreement – Apr. 8, 2002). We required the bank to strengthen internal controls to improve its information security program.

• Sequoia National Bank, San Francisco, California (consent order – Apr. 10,

2002). We required the bank to strengthen its internal controls to improve compliance with applicable consumer laws and regulations.

• The First National Bank of St. Marys, St. Marys, West Virginia (consent order –

Apr. 23, 2002). We required the bank to strengthen internal controls to improve its information security program and compliance with applicable consumer laws and regulations.

• Harbor Capital National Bank, Rockville, Maryland (formal agreement – May 6,

2002). We required the bank to strengthen its internal controls to improve compliance with applicable consumer laws and regulations.

• First National Bank of Germantown, Germantown, Ohio (amended consent order

– May 23, 2002). We required the bank to develop an information security program.

• Prime Pacific Bank, Lynnwood, Washington (formal agreement – June 12, 2002).

We required the bank to strengthen internal controls to improve its information security program.

• First National Bank of Limon, Limon, Colorado (formal agreement – July 10,

2002). We required the bank to strengthen its internal controls to improve compliance with applicable consumer laws and regulations.

• First National Bank, Ft. Pierre, South Dakota (formal agreement – July 18, 2002).

In this FTC Act action, we required the bank to change its marketing practices.

• The First National Bank of Mayfield, Mayfield, Kentucky (formal agreement – Aug. 21, 2002). We required the bank to strengthen its internal controls to improve compliance with applicable consumer laws and regulations.

• National Bank of Andover, Andover, Kansas (formal agreement – Sept. 26,

2002). We required the bank to strengthen internal controls to improve its information security program.

• First National Bank of Clinton, Clinton, Kentucky (formal agreement – Oct. 2,

2002). We required the bank to strengthen internal controls to improve its information security program.

• The First National Bank of Slippery Rock, Slippery Rock, Pennsylvania (formal

agreement – Oct. 15, 2002). We required the bank to strengthen its internal

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controls to improve its information security program and compliance with applicable consumer laws and regulations.

• Valley Bank (National Association), Elk Point, South Dakota (consent order –

Oct. 21, 2002). We required the bank to strengthen its internal controls to improve compliance with applicable consumer laws and regulations.

• ACE Cash Express, Inc. (consent order – Oct. 25, 2002). We required the

company to cease making payday loans through national banks and to pay a civil money penalty of $250,000.

• Goleta National Bank, Goleta, California (consent order – Oct. 28, 2002). We

required the bank to cease making payday loans through ACE Cash Express, Inc., to notify consumers of missing loan files, and to pay a civil money penalty of $75,000.

• The Dublin National Bank, Dublin, Texas (formal agreement – Dec. 17, 2002).

We required the bank to adjust the accounts of all customers who received inaccurate disclosures under the Truth in Lending Act and Regulation Z and to strengthen its internal controls to improve compliance with applicable consumer laws and regulations.

2001:

• The American National Bank of Mount Pleasant, Mount Pleasant, Texas (formal agreement – March 28, 2001). We required the bank to strengthen its internal controls to improve compliance with applicable consumer laws and regulations.

• The Palisades National Bank, Palisades, Colorado (formal agreement – March 29,

2001). We required the bank to strengthen its internal controls to improve compliance with applicable consumer laws and regulations.

• Direct Merchants Credit Card Bank, N.A., Scottsdale, Arizona (consent order –

May 3, 2001). In this FTC Act action, we required the bank to provide restitution of approximately $3.2 million and to change its credit card marketing practices.

• The First National Bank of Shamrock, Shamrock, Texas (formal agreement –

May 5, 2001). We required the bank to strengthen its internal controls to improve compliance with applicable consumer laws and regulations.

• Gold Country National Bank, Brownsville, California (amendment to formal

agreement – May 24, 2001). We required the bank to strengthen its internal controls to improve compliance with applicable consumer laws and regulations.

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• Granite National Bank, Bowling Green, Ohio (consent order – June 21, 2001). We required the bank to strengthen its internal controls to improve compliance with applicable consumer laws and regulations.

• Ballston Spa National Bank, Ballston Spa, New York (formal agreement – June

28, 2001). We required the bank to strengthen internal controls to improve its information security program.

• Union Bank of Arizona, N.A., Gilbert, Arizona (formal agreement – June 28,

2001). We required the bank to correct deficiencies in its information security program.

• National Bank of Malvern, Malvern, Pennsylvania (formal agreement – Aug. 6,

2001). We required the bank to strengthen internal controls to improve its information security program.

• Marine National Bank of Naples, Naples, Florida (formal agreement – Sept. 10,

2001). We required the bank to strengthen internal controls to improve its information security program and compliance with applicable laws and regulations.

• Claritybank.com, N.A., Uvalde, Texas (formal agreement – Sept. 20, 2001). We

required the bank to strengthen internal controls to improve its information security system.

• First National Bank of Gillette, Gillette, Wyoming (formal agreement – Oct. 2,

2001). We required the bank to strengthen its internal controls to improve compliance with applicable consumer laws and regulations.

• Neighborhood National Bank, San Diego, California (formal agreement – Nov.

19, 2001). We required the bank to strengthen internal controls to improve its information security program.

• First National Bank of Marin, Las Vegas, Nevada (consent order – Dec. 3, 2001).

In this FTC Act action, we required the bank to set aside at least $4 million for restitution to affected consumers and to change its marketing practices.

• Eagle National Bank, Upper Darby, Pennsylvania (consent order – Dec. 18,

2001). We required the bank to cease making payday loans.

2000:

• Farmers National Bank of Forney, Forney, Texas (formal agreement – March 6, 2000). We required the bank to strengthen its internal controls to improve compliance with applicable consumer laws and regulations.

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• Goleta National Bank, Goleta, California (formal agreement – March 23, 2000). We required the bank to strengthen its internal controls to improve compliance with applicable consumer laws and regulations.

• Sleepy Hollow National Bank, Sleepy Hollow, New York (formal agreement –

Apr. 6, 2000). We required the bank to strengthen its internal controls to improve compliance with applicable consumer laws and regulations.

• Providian National Bank, Tilton, New Hampshire (consent order – June 28,

2000). We required the bank to set aside not less than $300 million for restitution to affected consumers and to change its credit card marketing program, policies, and procedures.

• First National Bank, Fairfield, Texas (formal agreement – July 18, 2000). We

required the bank to strengthen its internal controls to improve compliance with applicable consumer laws and regulations.

• Founders Trust National Bank, Sioux Falls, South Dakota (consent order – July

19, 2000). We required the bank to strengthen its internal controls to improve compliance with applicable consumer laws and regulations.

• Gold Country National Bank, Brownsville, California (formal agreement – Sept.

7, 2000). We required the bank to strengthen its internal controls to improve its information security program.

• First Suburban National Bank, Maywood, Illinois (formal agreement – Sept. 11,

2000). We required the bank to ensure compliance with a written consumer compliance program adopted pursuant to a previous agreement.

• Community National Bank of Tennessee, Lexington, Tennessee (formal

agreement – Sept. 20, 2000). We required the bank to strengthen its internal controls to improve its information security program and compliance with applicable consumer laws and regulations.

• net First National Bank, Boca Raton, Florida (consent order – Sept. 25, 2000).

We required the bank to cease certain marketing activities in connection with a credit card program and to cease the commencement of any new credit card program until it had corrected deficiencies.

• Heartland Bank, National Association, Racine, Ohio (formal agreement – Sept.

26, 2000). We required the bank to strengthen its internal controls to improve compliance with applicable consumer laws and regulations.

• Stebbins National Bank, Creston, Ohio (formal agreement – Sept. 26, 2000). We

required the bank to strengthen its internal controls to improve compliance with applicable consumer laws and regulations.

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• Gateway National Bank, St. Louis, Missouri (formal agreement – Oct. 27, 2000).

We required the bank to strengthen its internal controls to improve compliance with applicable consumer laws and regulations.

• Sequoia National Bank, San Francisco, California (formal agreement – Nov. 15,

2000). We required the bank to strengthen its internal controls to improve its information security program.

Oct. 1, 1999 to Dec. 31, 1999:

• Community Bank & Trust, N.A. (formal agreement – Oct. 1, 1999). We required the bank to strengthen its internal controls to improve compliance with applicable consumer laws and regulations.

• First National Bank, Telluride, Colorado (formal agreement – Oct. 26, 1999). We

required the bank to strengthen its internal controls to improve compliance with applicable consumer laws and regulations.

• The Malta National Bank, Malta, Ohio (formal agreement – Oct. 28, 1999). We

required the bank to strengthen its internal controls to improve compliance with applicable consumer laws and regulations.

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Appendix B

OCC Informal Enforcement and Other Supervisory Actions in the Consumer Protection Area

2009:

Informal Enforcement Actions: The OCC entered into two memoranda of understanding and required one commitment letter. The issues addressed included requiring restitution for Equal Credit Opportunity Act and Regulation B violations and strengthening consumer compliance controls. Regulation Z reimbursement directives: 31

Matters Requiring Attention: 1592 2008:

Informal Enforcement Actions: The OCC required one commitment letter relating to strengthening the bank’s consumer compliance controls. Regulation Z reimbursement directives: 11

Matters Requiring Attention: 236 2007:

Informal Enforcement Actions: The OCC entered into one memorandum of understanding and required one commitment letter relating to strengthening the banks’ consumer compliance controls. Regulation Z reimbursement directives: 4

Matters Requiring Attention: 185

1 Regulation Z reimbursement directives are sometimes, but not always, issued in conjunction with MRAs or formal or enforcement actions. 2 Significant problems that are discovered in examinations are communicated to bank management in the form of Matters Requiring Attention (MRAs) in Reports of Examination or Supervisory Letters. Activities in response to MRAs are tracked in OCC databases and remain open until examiners determine that the concerns have been addressed. Failure by bank management to address MRAs may lead to an enforcement action. The number in the text includes consumer protection related MRAs issued in a particular year, addressing matters such as the need to improve internal controls to prevent violations of laws, rules or regulations from occurring or to correct violations cited as a result of examinations. Although MRAs issued with respect to credit administration issues such as inadequate underwriting controls have consumer protection implications, we have not included these in the numbers in the text.

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2006:

Informal Enforcement Actions: The OCC entered into three memoranda of understanding and required one safety and soundness plan under 12 C.F.R. Part 30 relating to strengthening the banks’ consumer compliance controls. Regulation Z reimbursement directives: 16

Matters Requiring Attention: 203 2005:

Informal Enforcement Actions: The OCC entered into eight memoranda of understanding, required three commitment letters, and required one safety and soundness plan. The issues addressed included correcting violations of Regulation B, the Home Mortgage Disclosure Act, and the Fair Credit Reporting Act, ensuring that credit card solicitations were not misleading or deceptive, adjusting consumer accounts as a result of Regulation Z violations, strengthening consumer compliance controls, and strengthening controls for safeguarding customer information. Regulation Z reimbursement directives: 9

Matters Requiring Attention: 167 2004:

Informal Enforcement Actions: The OCC entered into three memoranda of understanding, required one commitment letter, and required one safety and soundness plan. The issues addressed included ensuring that credit card solicitations were not misleading or deceptive, strengthening consumer compliance controls, and strengthening controls for safeguarding customer information. Regulation Z reimbursement directives: 11

Matters Requiring Attention: 127 2003:

Informal Enforcement Actions: The OCC entered into five memoranda of understanding and required two commitment letters. The issues addressed included remedying Regulation B violations resulting from a bank’s credit card scoring system, strengthening consumer compliance controls, and strengthening controls for safeguarding customer information.

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Regulation Z reimbursement directives: 15 Matters Requiring Attention: 146 2002:

Informal Enforcement Actions: The OCC entered into five memoranda of understanding relating to strengthening the banks’ consumer compliance controls. Regulation Z reimbursement directives: 19

Matters Requiring Attention: 149 2001:

Informal Enforcement Actions: The OCC entered into two memoranda of understanding and required one Board of Directors resolution. The issues addressed included remedying and preventing Equal Credit Opportunity Act and Regulation B violations in credit card lending and strengthening consumer compliance controls. Regulation Z reimbursement directives: 19

Matters Requiring Attention: 124 2000:

Informal Enforcement Actions: The OCC entered into two memoranda of understanding and required two Board of Directors resolutions. The issues addressed included adjusting accounts for consumers who received inaccurate disclosures under Regulation Z and strengthening consumer compliance controls. Regulation Z reimbursement directives: 5

Matters Requiring Attention: 48

Oct. 1, 1999 to Dec. 31, 1999:

Regulation Z reimbursement directives: 1

Matters Requiring Attention: 3

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Appendix C

OCC Regulations and Guidance on Consumer Protection and Community Reinvestment Issues1

2009:

• Guidance, OCC Bulletin 2009-29, “Guidance on Truth in Lending Act Interim Final Rules” (August 26, 2009) (advising national banks to disclose, if applicable, that consumers cannot reject the application of new terms to transactions that occur more than 14 days after the provision of a change-in-terms notice).

• Examination Procedures, “Other Consumer Laws and Regulations” (revised August 13, 2009).

• Guidance, OCC Bulletin 2009-28, “Helping Families Save Their Homes Act of 2009 – Title VII Tenant Protections” (August 13, 2009).

• Guidance, OCC Bulletin 2009-25, “Credit CARD Act of 2009-Interest Rate Increases/Consumer Protections: Guidance” (July 30, 2009).

• Joint Final Rules, “Interagency Procedures to Enhance the Accuracy and Integrity of Information Furnished to Consumer Reporting Agencies under Section 312 of the Fair and Accurate Credit Transactions Act,” 12 CFR part 41, 74 FR 31,484 (July 1, 2009; proposed December 13, 2007; ANPR March 22, 2006).

• Joint Proposed Rules, “Community Reinvestment Act,” 12 CFR part 25, 74 FR 31,209 (June 30, 2009) (addressing low-cost education loans to low-income borrowers and majority-owned banks’ activities in connection with minority- or women-owned financial institutions and low-income credit unions).

• Joint Guidance, “Frequently Asked Questions: Identity Theft Red Flags and Address Discrepancies” (June 11, 2009).

• Joint Proposed Rules, “S.A.F.E. Act Mortgage Loan Originator Registration Requirements,” 74 FR 27,386 (June 9, 2009).

• Joint Final Rules; Technical Corrections, “Fair Credit Reporting Affiliate Marketing Regulations; Identity Theft Red Flags and Address Discrepancies under the Fair and Accurate Credit Transactions Act of 2003,” 12 CFR part 41, 74 FR 22,639 (May 14, 2009).

• Final Rule, “Community and Economic Development Entities, Community Development Projects, and Other Public Welfare Investments,” 12 CFR part 24, 74 FR 15,657 (April 7, 2009; interim final rule August 11, 2008) (implementing changes to 12 U.S.C. 24 (Eleventh) by the Housing and Economic Recovery Act of 2008).

• Joint Guidance, “Interagency Questions and Answers on Community Reinvestment,” 74 FR 498 (January 6, 2009; proposed July 11, 2007).

1 OCC guidance and regulations may generally be found on the OCC Web site at http://www.occ.treas.gov/OCC_current.htm, http://www.occ.treas.gov/OCC_current.htm, or http://www.occ.treas.gov/altlst09.htm.

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2008:

• Examination Procedures, “Truth in Savings Act – Regulation DD” (revised November 19, 2008).

• Guidance, OCC Bulletin 2008-30, “Servicemembers Civil Relief Act: Legal Requirements” (October 24, 2008).

• Examination Procedures, “Fair Credit Reporting Act – Additions to FCRA Examination Procedures” (October 15, 2008).

• Examination Procedures, “Truth in Lending” (updated October 6, 2008). • Guidance, OCC Bulletin 2008-26, “Responding to Disasters: Supervisory

Guidance” (October 3, 2008). • Guidance, OCC Bulletin 2008-24, “Community Reinvestment Act: Hurricanes

Katrina and Rita” (September 29, 2008) (extending time for CRA consideration of activities in those designated disaster areas).

• “OCC Policy Statement on Minority-Owned National Banks” (updated September 24, 2008).

• Joint Final Guidance, “Interagency Illustrations of Consumer Information for Hybrid Adjustable Rate Mortgage Products,” 73 FR 30,997 (May 29, 2008; proposed August 14, 2007).

• Guidance, OCC Bulletin 2008-9, “Community Reinvestment Act: Income Level, Median Family Income [for 2008]” (March 24, 2008).

2007:

• Joint Final Rules and Guidelines, “Identity Theft Red Flags and Address Discrepancies under the Fair and Accurate Credit Transactions Act of 2003,” 12 CFR part 41, 72 FR 63,718 (November 9, 2007; proposed July 18, 2006).

• Joint Final Rules, “Fair Credit Reporting Affiliate Marketing Regulations,” 72 FR 62,910 (November 7, 2007; proposed July 15, 2004).

• Joint Guidance, OCC Bulletin 2007-38, “Working with Borrowers: Statement on Residential Real Estate Loan Restructurings for Serviced Loans” (October 11, 2007).

• Joint Proposed Guidance, “Proposed Guidance on Garnishment of Exempt Federal Benefit Funds,” 72 FR 55,273 (September 28, 2007).

• OCC Alert, “Debt Elimination Fraud: Fraudulent Schemes to Eliminate Mortgage, Credit Card, or Small Business Debt” (September 5, 2007).

• Examination Procedures, “Telephone Consumer Protection Act and Junk Fax Prevention Act” (revised August 24, 2007).

• Joint Final Guidance, “Interagency Statement on Subprime Mortgage Lending,” 72 FR 37,569 (July 25, 2007; proposed March 8, 2007).

• Joint Final Guidance, “Illustrations of Consumer Information for Nontraditional Mortgage Products,” 72 FR 31,825 (June 8, 2007; proposed October 4, 2006).

• Guidance, OCC Bulletin 2007-14, “Working with Mortgage Borrowers: Interagency Statement” (April 18, 2007) (working with borrowers facing default or foreclosure).

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• Joint Proposed Rules, “Interagency Proposal for Model Privacy Form under the Gramm-Leach Bliley Act,” 72 FR 14,939 (April 5, 2007; ANPR December 30, 2003).

2006:

• Guidance, OCC Bulletin 2006-44, “Public Welfare Investments: Increase in Investment Limits” (October 23, 2006).

• Guidance, OCC Bulletin 2006-43, “Home Equity Lending: Addendum to OCC Bulletin 2005-22” (October 4, 2006) (addressing communications with consumers).

• Joint Final Guidance, “Interagency Guidance on Nontraditional Mortgage Product Risks,” 71 FR 52,609 (October 4, 2006; proposed December 29, 2005).

• OCC Alert, “Customer Authentication and Internet Banking Alert” (September 8, 2006).

• Guidance, OCC Bulletin 2006-37, “Telephone Consumer Protection Act: Do-Not-Call List Requirements” (August 22, 2006).

• Guidance, OCC Bulletin 2006-34, “Gift Card Disclosures: Guidance on Disclosure and Marketing Issues” (August 14, 2006).

• Joint Guidance, OCC Bulletin 2006-31, “FFIEC Information Security Booklet” (July 27, 2006).

• Guidance, “Disaster Planning: Hurricane Katrina: Lessons Learned” (June 15, 2006).

• Interagency Examination Procedures, “Community Reinvestment Act Examination Procedures for Large, Small, Wholesale/Limited Purpose, and Strategic Plan Institutions” (revised April 6, 1006).

• Examination Procedures, “Fair Lending” (revised April 2006). • Joint Guidance, “Frequently Asked Questions about the New HMDA Data”

(updated April 3, 2006). • Examination Procedures, “Controlling the Assault of Non-Solicited Pornography

and Marketing Act of 2003 (CAN-SPAM)” (March 30, 2006). • Joint Advisory, “Influenza Pandemic Preparedness” (March 15, 2006). • Joint Guidance, “Questions and Answers Regarding Community Reinvestment,”

71 FR 12,424 (March 10, 2006; proposed November 10, 2005). • Joint Guidance, OCC Bulletin 2006-6, “Community Reinvestment Act:

Hurricanes Katrina and Rita” (February 9, 2006). • Joint Guidance, “Hurricane Katrina: Guidance to Examiners” (February 3, 2006).

2005:

• Interagency Compliance Guide, “Interagency Guidelines for Establishing Information Security Standards” (December 14, 2005).

• Interagency Examination Procedures, “Community Reinvestment: Intermediate Small Institutions” (August 24, 2005).

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• Joint Final Rules, “Fair Credit Reporting Medical Information Regulations,” 12 CFR 41, 70 FR 70,664 (November 22, 2005) (interim final rule June 10, 2005; proposed April 28, 2004).

• Interagency Statement and Order, “Hurricanes Katrina and Rita: Real Estate Appraisal Exemptions in Major Disaster Areas,” 70 FR 59,987 (October 14, 2005).

• Joint Guidance, “Authentication in an Internet Banking Environment” (October 12, 2005).

• Supervisory Guidance, “Hurricane Katrina” (September 19, 2005). • Interagency Examination Procedures, “Community Reinvestment Act” (August

24, 2005). • Joint Final Rules, “Community Reinvestment Act Regulations,” 12 CFR part 25,

70 FR 44,256, (August 2, 2005; re-proposed March 11, 2005; proposed February 6, 2004; ANPR July 19, 2001) (adopting “intermediate small bank” performance standards and expanding definition of “community development”).

• Examination Procedures, “Home Mortgage Disclosure Act” (revised July 2005). • Guidance, OCC Bulletin 2005-22, “Home Equity Lending: Credit Risk

Management Guidance” (May 16, 2005). • Joint Guidance, “Frequently Asked Questions about the New HMDA Data”

(March 31, 2005). • Joint Guidance, “Interagency Guidance on Response Programs for Unauthorized

Access to Customer Information and Customer Notice,” 70 FR 15,736 (March 29, 2005; proposed August 12, 2003).

• Joint Final Rules, “Community Reinvestment Act Regulations,” 12 CFR part 25, 70 FR 15,570 (March 28, 2005; joint interim rule July 8, 2004) (conforming terms in CRA regulation with terms in other recently revised regulations).

• Joint Guidance, “Joint Guidance on Overdraft Protection Programs,” 70 FR 9,127 (February 24, 2005; proposed June 7, 2004).

• Guidelines, “OCC Guidelines Establishing Standards for Residential Mortgage Lending Practices,” 12 CFR part 30, 70 FR 6,320 (February 7, 2005)

• OCC Bulletin 2005-3 and Explanatory Guidance, “How the OCC’s Part 30 Enforcement Process Can Address Predatory Lending” (February 2, 2005).

2004:

• Joint Final Rules, “Proper Disposal of Consumer Information under the Fair and Accurate Credit Transactions Act of 2003,” 12 CFR parts 30 and 41, 69 FR 77,610 (December 28, 2004; proposed June 8, 2004).

• Final Rule, “Rules, Policies, and Procedures for Corporate Activities; Annual Report on Operating Subsidiaries,”12 CFR part 5, 69 FR 64478 (November 5, 2004; proposed March 25, 2004) (to assist consumers in identifying subsidiaries subject to OCC supervisory authority).

• Guidance, AL 2004-11, “Electronic Consumer Disclosures and Notices” (October 1, 2004).

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• Guidance, AL 2004-10, “Credit Card Practices” (September 14, 2004) (addressing unacceptable credit card marketing and account management practices).

• Compliance Software, “Release of APRWIN 6.0 and APYWIN 2.0” (May 12, 2004).

• Guidance, AL 2004-6, “Payroll Card Systems” (May 6, 2004). • Guidance, AL 2004-4, “Secured Credit Cards” (April 28, 2004). • Guidance, AL 2004-2, “Consumer Complaints Referred to National Banks from

State Officials” (March 1, 2004). • Final Rule, “Bank Activities and Operations; Real Estate Lending and

Appraisals,” 12 CFR parts 7 and 34, 69 FR 1,904 (January 13, 2004; proposed August 5, 2003) (part 34: prescribes an explicit anti-predatory lending standard for real estate loans; part 7: prescribes an explicit anti-predatory lending standard for non-real estate loans).

2003:

• OCC Alert, “Customer Identity Theft: E-Mail-Related Fraud Threats (Phishing)” (September 12, 2003).

• Final Rule, “Community and Economic Development Entities, Community Development Projects, and Other Public Welfare Investments,” 12 CFR part 24, 68 FR 48,771 (August 15, 2003; proposed January 10, 2003) (updates the regulation to include additional approved types of investments and adopts CD-1 form to be used when making a public welfare investment).

• Examination Procedures, “Homeownership Counseling” (June 30, 2003). • Interagency Guidance, “Weblinking: Identifying Risks and Risk Management

Techniques” (April 22, 2003). • Guidance, AL 2003-3, “Avoiding Predatory and Abusive Lending Practices in

Brokered and Purchased Loans” (February 21, 2003). • Guidance, AL 2003-2, “Guidelines for National Banks to Guard against Predatory

and Abusive Lending Practices” (February 21, 2003). • Interagency Guidance, “Credit Card Lending: Account Management and Loss

Allowance Guidance” (January 8, 2003). 2002:

• Final Rule, “Debt Cancellation Contracts and Debt Suspension Agreements,” 12 CFR parts 7 and 37, 67 FR 58,962 (September 19, 2002; proposed April 18, 2001; ANPR January 26, 2000; compliance date delay June 13, 2003).

• Examination Procedures, “Children’s Online Privacy Protection Act (COPPA)” (July 16, 2002).

• Guidance, OCC Bulletin 2002-27, “Homeownership Counseling: Notice of Statutory Requirement” (June 17, 2002).

• Guidance, AL 2002-3, “Guidance on Unfair or Deceptive Acts or Practices” (March 22, 2002).

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• Joint Guidance, “Real Estate Settlement Procedures Act: Examiner Guidance – Mark-Up of Settlement Service Fees” (January 15, 2002).

2001:

• Guidance, “Privacy of Consumer Financial Information: Small Bank Compliance Guide” (December 12, 2001).

• Guidance, OCC Bulletin 2001-47, “Third-Party Relationships: Risk Management Principles” (November 1, 2001).

• Joint Guidance, “Consumer Protections for Depository Institution Sales of Insurance” (September 14, 2001).

• Guidance, AL 2001-9, “Electronic Fund Transfer Act – Investigations of Unauthorized Transactions” (September 7, 2001).

• Examination Procedures, “Procedures to Evaluate Compliance with the Guidelines to Safeguard Customer Information” (July 18, 2001).

• Joint Guidance, “Questions and Answers Regarding Community Reinvestment,” 66 FR 36,620 (July 12, 2001).

• Guidance, AL 2001-6, “Fair Credit Reporting Act” (July 6, 2001). • Guidance, OCC Bulletin 2001-31, “Weblinking” (July 3, 2001). • Joint Guidance, “A Guide to CRA Data Collection and Reporting” (May 8, 2001). • Examination Procedures, “Privacy of Consumer Financial Information” (May 25,

2001). • Guidance, AL 2001-4, “Identity Theft and Pretext Calling” (April 30, 2001). • OCC Alert, “Network Security Vulnerabilities” (April 24, 2001). • Interagency Release, “Federal Banking Agencies Will Allow Privacy Notices

under Existing Fair Credit Reporting Act” (March 14, 2001). • Joint Final Rules, “Interagency Guidelines Establishing Standards for

Safeguarding Customer Information and Rescission of Year 2000 Standards for Safety and Soundness,” 12 CFR part 30, 66 FR 8,615 (February 1, 2001; proposed June 26, 2000).

• Joint Guidance, “Subprime Lending: Expanded Guidance for Subprime Lending Programs” (January 31, 2001).

• Advisory Letter, AL 2001-2, “Privacy Preparedness” (January 22, 2001). • Guidance, “Financial Literacy Resource Directory” (January 17, 2001). • Guidance, AL 2001-1, “Financial Literacy” (January 16, 2001). • Joint Final Rules, “Disclosure and Reporting of CRA-Related Agreements,” 12

CFR part 35, 66 FR 2,051 (January 10, 2001; proposed May 19, 2000). 2000:

• OCC Examiner Guidance, “Large Bank Community Reinvestment Act Examinations” (December 29, 2000).

• Joint Final Rules, “Consumer Protections for Depository Institution Sales of Insurance” 12 CFR part 14, 67 FR 75,821 (December 4, 2000; proposed August 21, 2000).

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• Guidance, AL 2000-10, “Payday Lending” (November 27, 2000). • Guidance, AL 2000-11, “Title Loan Programs” (November 27, 2000). • Resource Booklet, “Privacy Laws and Regulations” (September 8, 2000). • Joint Proposed Rules, “Fair Credit Reporting Regulations,” 12 CFR part 41, 65

FR 63,120 (October 20, 2000; not finalized). • Guidance, AL 2000-7, “Abusive Lending Practices” (July 25, 2000). • OCC Alert, “Protecting Internet Addresses of National Banks” (July 19, 2000)

(warning that some Web site names may confuse bank customers). • Guidance, AL 2000-5, “Real Estate Settlement Procedures Act: Q&A on the

HUD-1 Settlement Statement” (June 2, 2000). • Joint Final Rule, “Privacy of Consumer Financial Information,” 12 CFR part 40,

65 FR 35,161 (June 1, 2000; proposed February 22, 2000). • Joint Guidance, FFIEC Advisory Letter, “Consumer Credit Reporting Practices”

(February 16, 2000). 1999:

• Final Rule, “Community Development Corporations, Community Development Projects, and Other Public Welfare Investments,” 12 CFR part 24, 66 FR 70,986 (December 20, 1999; proposed June 10, 1999) (simplifies the prior notice and self-certification process, allows expanded self-certification).

• Guidance, AL 99-12, “Year 2000 Information Security Precautions” (November 24, 1999).

• Joint Guidance, “Interagency Guidance on High LTV Residential Real Estate Lending” (October 8, 1999).

• Guidance, AL 99-10, “Year 2000-Related Fraud Prevention” (July 8, 1999). • Guidance, AL 99-7, “Year 2000 Checklist for Customers” (May 4, 1999). • Examination Procedures, “Community Reinvestment Act” (revised for Web

publication May 1999). • Guidance, AL 99-06, “Guidance to National Banks on Web Site Privacy

Statements” (May 4, 1999). • Guidance, “Subprime Lending: Risks and Rewards” (April 5, 1999). • Guidance, AL 99-03, “Fair Credit Reporting Act” (March 29, 1999). • Guidance, “Infrastructure Threats from Cyber-Terrorists” (March 5, 1999). • Guidance, AL 99-2, “Year 2000 Customer Communication Outline” (February

17, 1999). • Guidance, AL 99-1, “State CRA Laws,” January 26, 1999.

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Appendix D

OCC Speeches, Testimony, Consumer Advisories, and Other Public Communications Related to Consumer Protection1

2009: Speeches and Testimony

• John C. Dugan, Comptroller of the Currency, Remarks before the Interagency Community Affairs Conference, August 26, 2009 (discussing interagency work to promote community development).

• Ann F. Jaedicke, Deputy Comptroller for Compliance Policy, Testimony before the Special Committee on Aging of the U.S. Senate (June 29, 2009) (discussing reverse mortgages and their risks to consumers).

• John C. Dugan, Comptroller of the Currency, Remarks before American Bankers Association Regulatory Compliance Conference (June 9, 2009) (discussing reverse mortgages and their risks to consumers).

• John C. Dugan, Comptroller of the Currency, Testimony before the Committee on Financial Services of the U.S. House of Representatives (March 20, 2009) (discussing enforcement authority over fraud and other financial consumer protection standards).

• Barry R. Wides, Deputy Comptroller for Community Affairs, Statement before the United States Commission on Civil Rights (March 20, 2009) (discussing the Community Reinvestment Act and mortgage lending).

Consumer Advisories

• Consumer Advisory, CA 2009-2, “Reverse Mortgages: Are They for You?” (September 25, 2009).

• Public Service Announcement, “Understanding Reverse Mortgages” (print, script, and .mp3 formats).

• Consumer Advisory, CA 2009-1, “Consumer Tips for Avoiding Mortgage Modification Scams and Foreclosure Rescue Scams” (April 21, 2009).

• Public Service Announcement, “Don’t Be Burned by Debt Elimination Scams” (print, script, and .mp3 formats).

• Public Service Announcement, “Foreclosure Prevention: Help Save Your Home” (script and .mp3 formats).

1 OCC speeches may be found on the OCC Web site at http://www.occ.treas.gov/speeches.htm. OCC speeches, testimony, and other outreach materials may generally be found, along with relevant news releases, on the OCC Web site at http://www.occ.treas.gov/09rellst.htm. Community development materials may be found on the OCC Web site at http://www.occ.treas.gov/cdd/resource.htm.

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Other Public Communications

• Community Developments: Fact Sheet, “Individual Development Accounts” (July

2009). • Community Developments: Fact Sheet, “Rebuilding the Gulf Coast: How Banks

Can Help” (July 2009). • Letters from John C. Dugan, Comptroller of the Currency, to National Consumer

Law Center, Woodstock Institute, Neighborhood Economic Development Advocacy Project, California Reinvestment Coalition, Consumer Federation of America, and Community Reinvestment Association of North Carolina (May 20, 2009) (stating that strong consumer protection and risk management processes are appropriate with respect to refund anticipation loan products).2

• Community Developments: Insights, “School-Based Bank Savings Programs: Bringing Financial Education to Students” (April 29, 2009).

• Community Developments: Investments, “Cultivating Community-Based Financial Literacy Initiatives” (April 20, 2009).

• Community Developments: Insights, “Property Disposition: Exploring Different Approaches for Preserving Affordable Housing Opportunities” (March 10, 2009).

• Interagency Statement in Support of the “Making Home Affordable” Loan Modification Program (March 4, 2009).

• Publication, “Reaching New Bank Customers Through the Earned Income Tax Credit” (March 2009).

2008: Speeches and Testimony

• John C. Dugan, Comptroller of the Currency, Remarks before the Enterprise Annual Network Conference (November 19, 2008) (discussing the Community Reinvestment Act’s lack of responsibility for subprime lending abuses).

• Barry R. Wides, Deputy Comptroller for Community Affairs, Remarks before the HUD Summit on Housing: Partnering for Responsible Policy (October 7, 2008) (discussing opportunities for banks to partner with state and local organizations to mitigate the negative effects of mortgage defaults and foreclosures on communities).

• John C. Dugan, Comptroller of the Currency, Remarks before the 2008 OCC Fair Lending Conference (September 10, 2008) (discussing the importance of fair lending and OCC fair lending supervision).

• John C. Dugan, Comptroller of the Currency, Remarks before the Interagency Minority Depository Institutions National Conference (July 17, 2008) (discussing the challenges and opportunities facing minority-owned banks in the United States).

2 Letters available upon request.

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• Barry R. Wides, Deputy Comptroller for Community Affairs, Remarks before the Stabilizing Communities Symposium (July 15, 2008) (discussing innovative strategies for assisting borrowers and stabilizing communities).

• John C. Dugan, Comptroller of the Currency, Remarks before the Forum on Mortgage Lending for Low- and Moderate-Income Households (July 8, 2008) (discussing elements of a responsible mortgage lending product geared at low- and moderate-income populations).

• John C. Dugan, Comptroller of the Currency, Remarks before the OCC Compliance Conference (July 7, 2008) (discussing the importance of continuing to focus on consumer compliance).

• John C. Dugan, Comptroller of the Currency, Remarks before the American Securitization Forum (June 11, 2008) (introducing the mortgage metrics project, which will produce better mortgage information for supervisory purposes, and for policymakers, other regulators, market participants, and the public at large).

• Julie L. Williams, Chief Counsel and First Senior Deputy Comptroller, Testimony before the Subcommittee on Financial Institutions and Consumer Credit of the Committee on Financial Services of the U.S. House of Representatives (April 17, 2008) (discussing credit card lending).

• Barry R. Wides, Deputy Comptroller for Community Affairs, Testimony before the Committee on Financial Services of the U.S. House of Representatives (April 15, 2008) (discussing the OCC’s involvement in and perspectives on governmental and private sector financial literacy and education initiatives).

• John C. Dugan, Comptroller of the Currency, Testimony before the Committee on Financial Services of the U.S. House of Representatives (April 9, 2008) (discussing the proposed FHA Housing Stabilization and Homeownership Retention Act of 2008).

• Ann F. Jaedicke, Deputy Comptroller for Compliance Policy, Testimony before the Committee on Financial Services of the U.S. House of Representatives (February 13, 2008) (discussing the effectiveness of the Community Reinvestment Act).

• John C. Dugan, Comptroller of the Currency, Remarks before the National Association of Affordable Housing Lenders (February 12, 2008) (discussing the future role of community reinvestment and public welfare investments).

Consumer Advisories

• Interagency Consumer Brochure, “You Have the Power to Stop Identity Theft”

(updated December 22, 2008). • Public Service Announcements, “Your Money: What You Can Do to Fight

Fraud” (print, script, and .mp3 formats). • Consumer Advisory, CA 2008-1, “Consumer Tips for Avoiding Mortgage

Modification Scams and Foreclosure Rescue Scams” (May 16, 2008, superseded by CA 2009-1).

• Public Service Announcement, “Beware of Foreclosure Prevention Scams” (print, script, and .mp3 formats)

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• Public Service Announcement, “Preventing Foreclosures” (script and .mp3 formats).

Other Public Communications

• Community Developments Newsletter, “Gulf Coast Redevelopment: Pathways to Recovery (Fall 2008).

• Letter from John C. Dugan, Comptroller of the Currency, to Jennifer J. Johnson, Secretary, Board of Governors of the Federal Reserve System (August 18, 2008) (commenting on the Board’s proposed rule amending the provisions of Regulation AA).3

2007:

Speeches and Testimony • John G. Walsh, Chief of Staff and Public Affairs, Testimony before the

Subcommittee on Financial Institutions and Consumer Credit of the Committee on Financial Services of the U.S. House of Representatives (December 12, 2007) (supporting efforts to establish a single, toll-free number for bank customers seeking regulator assistance).

• John C. Dugan, Comptroller of the Currency, Testimony before the Committee on Financial Services of the U.S. House of Representatives (December 6, 2007) (discussing enhancing the pace of mortgage loan modifications that may help troubled borrowers remain in their homes).

• Julie L. Williams, Chief Counsel and First Senior Deputy Comptroller, Remarks before the Joint Center for Housing Studies, Harvard University, National Symposium on “Understanding Consumer Credit: Expanding Access, Informing Choices, and Protecting Consumers” (November 28, 2007) (discussing different approaches to consumer protection regulation of consumer credit).

• John G. Walsh, Chief of Staff and Public Affairs, Testimony before the Subcommittee on Oversight and Investigations of the Committee on Financial Services of the U.S. House of Representatives (October 30, 2007) (discussing the actions that the OCC has taken toward the preservation and promotion of minority-owned financial institutions).

• Ann F. Jaedicke, Deputy Comptroller for Compliance Policy, Testimony before the Subcommittee on Domestic Policy of the Committee on Oversight and Government Reform of the U.S. House of Representatives (October 24, 2007) (discussing the OCC’s fair lending and Community Reinvestment Act examination processes).

• John C. Dugan, Comptroller of the Currency, Testimony before the Committee on Financial Services of the U.S. House of Representatives (October 24, 2007) (discussing H.R.3915, the “Mortgage Reform and Anti-Predatory Lending Act of 2007”).

3 Letter available upon request.

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• John C. Dugan, Comptroller of the Currency, Remarks before the Interagency Consumer Complaint Conference (October 15, 2007) (discussing the importance of handling consumer complaints and the use of technology in doing so).

• John G. Walsh, Chief of Staff and Public Affairs, Remarks before the National Bankers Association (October 10, 2007) (discussing OCC’s minority bank initiatives).

• John C. Dugan, Comptroller of the Currency, Remarks before the Financial Services Roundtable (September 27, 2007) (urging a rule that allows consumers to opt out of higher credit card rates).

• Julie L. Williams, Chief Counsel and First Senior Deputy Comptroller, Testimony before the Committee on Finance of the U.S. Senate (September 20, 2007) (discussing hardships created by garnishment of Federal benefit funds).

• John G. Walsh, Chief of Staff and Public Affairs, Remarks before the Interagency Minority Depository Institutions National Conference (August 1, 2007) (discussing topics affecting minority-owned institutions).

• Calvin R. Hagins, Director for Compliance Policy, Testimony before the Subcommittee on Oversight and Investigations of the Committee on Financial Services of the U.S. House of Representatives (July 25, 2007) (discussing fair lending issues and how the OCC supervises national banks to ensure compliance with fair lending laws).

• John C. Dugan, Comptroller of the Currency, Remarks before the NeighborWorks America Symposium on Promoting Foreclosure Solutions (June 25, 2007) (promoting improved lender contact with borrowers to help prevent foreclosures).

• John C. Dugan, Comptroller of the Currency, Testimony before the Committee on Financial Services of the U.S. House of Representatives (June 13, 2007) (discussing national bank supervision to ensure banks’ compliance with Federal consumer protection standards).

• John C. Dugan, Comptroller of the Currency, Testimony before the Subcommittee on Financial Institutions and Consumer Credit of the Committee on Financial Services of the U.S. House of Representatives (June 7, 2007) (discussing issues affecting the credit card market, including better credit card disclosures).

• John C. Dugan, Comptroller of the Currency, Remarks before the Neighborhood Housing Services of New York (May 23, 2007) (expressing concern over the acceptance by lenders of unverified, “stated income” from subprime borrowers as an appropriate measure of the borrowers’ capacity to repay their loans).

• John C. Dugan, Comptroller of the Currency, Remarks before the National Foundation for Credit Counseling Spring Meeting (April 24, 2007) (discussing the increase in subprime lending and mortgage foreclosures).

• John C. Dugan, Comptroller of the Currency, Remarks before the Greenlining Coalition’s 14th Annual Economic Summit (April 19, 2007) (discussing the effectiveness of the Community Reinvestment Act and the OCC’s effective regulation and supervision of national bank’s subprime lending to prevent abuses).

• Emory W. Rushton, Senior Deputy Comptroller and Chief National Bank Examiner, Testimony before the Subcommittee on Financial Institutions and Consumer Credit of the Committee on Financial Services of the U.S. House of

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Representatives (March 27, 2007) (discussing developments in mortgage underwriting and marketing practices, particularly in the subprime market, that have been the focus of attention by the OCC).

• Emory W. Rushton, Senior Deputy Comptroller and Chief National Bank Examiner, Testimony before the Committee on Banking, Housing, and Urban Affairs of the U.S. Senate (March 22, 2007) (discussing subprime mortgage lending and the OCC’s supervision of national banks).

• John C. Dugan, Comptroller of the Currency, Remarks before the ABA Financial Literacy Program Telephone Briefing (January 18, 2007) (discussing the importance of successful, results-oriented financial literacy programs).

• John C. Dugan, Comptroller of the Currency, Remarks before the Exchequer Club and Women in Housing and Finance (January 17, 2007) (discussing the OCC’s consumer complaint function).

Consumer Advisories

• News Release 2007-127, “OCC Reminds Consumers to Read Gift Cards’ Fine Print” (November 21, 2007).

• Public Service Announcement, “A Wrap Up on Gift Cards” (print, script, and .mp3 formats).

• Consumer Alert, “Solicitations Regarding Certain Mortgage Programs” (March 29, 1007) (alerting consumers to deceptive solicitations that refer to a “Community Reinvestment Act (CRA) Program” that entitles certain homeowners to cash grants or equity disbursements).

• Consumer Advisory, CA 2007-1, “Tips on Avoiding Cashier’s Check Fraud” (January 16, 2007).

• Public Service Announcement, “Watch Out for Check Fraud” (print, script, and .mp3 formats).

• Public Service Announcement, “HelpWithMyBank.gov: Good News for People with Banking Questions” (script and .mp3 formats).

• Public Service Announcement, “HelpWithMyBank.gov: Help Available Online” (script and .mp3 formats). Other Public Communications

• Letter from John C. Dugan, Comptroller of the Currency, to Jennifer J. Johnson,

Secretary, Board of Governors of the Federal Reserve System (October 12, 2007) (commenting on the Board’s proposed rule relating to the open-end credit provisions of the Truth in Lending Act, Regulation Z, and the related staff commentary).4

• Pamphlet, “Internet Merchant Acquisition and Monitoring Best Practices for the Prevention and Detection of Commercial Child Pornography” (August 9, 2007) (with the Financial Coalition Against Child Pornography).

4 Letter available upon request.

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• Community Developments: Insights, “Understanding Employer-Assisted Mortgage Programs: A Primer for National Banks” (August 2007).

• Launch of Web site, www.HelpWithMyBank.gov (July 16, 2007) (dedicated to providing answers and assistance to national bank customers).

• Downloadable Form, “Consumer Illustrations of Information on Nontraditional Mortgage Products” (July 5, 2007) (made available in English and Spanish).

• Community Developments: Insights, “Foreclosure Prevention: Improving Contact with Borrowers” (June 26, 2007).

• Interagency Statement, “Statement on Working with Mortgage Borrowers” (April 17, 2007).

2006: Speeches and Testimony

• John C. Dugan, Comptroller of the Currency, Remarks before the Pittsburgh Community Reinvestment Group (November 16, 2006) (discussing the risks of nontraditional mortgage products).

• John C. Dugan, Comptroller of the Currency, Remarks before America’s Community Bankers (October 17, 2006) (discussing the interagency nontraditional mortgage guidance and urging comparable standards applicable to all lenders).

• John C. Dugan, Comptroller of the Currency, Remarks before the National Bankers Association (October 12, 2006) (discussing OCC efforts to assist minority-owned banks in strengthening their operations and financial performance).

• Kathryn E. Dick, Deputy Comptroller, Testimony before the Subcommittee on Economic Policy and the Subcommittee on Housing and Transportation of the Committee on Banking, Housing, and Urban Affairs of the U.S. Senate (September 20, 2006) (discussing nontraditional mortgage products and the interagency nontraditional mortgage guidance).

• John C. Dugan, Comptroller of the Currency, Remarks at NeighborWorks Week 2006 (June 10, 2006) (discussing innovative partnerships to promote the public welfare).

• John G. Walsh, Chief of Staff and Public Affairs, Remarks before the National Housing Advisory Council (June 7, 2006) (discussing the interagency nontraditional mortgage guidance).

• John C. Dugan, Comptroller of the Currency, Remarks before the Conference on Bank Structure and Supervision (May 19, 2006) (discussing the changing financial business landscape and concerns about nontraditional residential mortgages).

• John C. Dugan, Comptroller of the Currency, Remarks before the Anacostia Economic Summit (May 3, 2006) (discussing banks’ responsibility to meet the credit needs of all of the communities in which they establish branches).

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• John C. Dugan, Comptroller of the Currency, Remarks before the Greenlining Coalition’s 13th Annual Economic Summit (April 20, 2006) (expressing concerns over increased use of nontraditional mortgage products).

• Julie L. Williams, Chief Counsel and First Senior Deputy Comptroller, Remarks before the University of North Carolina School of Law 2006 Banking Institute (March 30, 2006) (urging improved consumer financial disclosures).

• John C. Dugan, Comptroller of the Currency, Remarks before the Gulf Coast Bankers Conference (March 2, 2006) (discussing agency efforts to assist banks affected by hurricanes).

• John C. Dugan, Comptroller of the Currency, Remarks before the ALI-ABA Financial Services Institute (February 2, 2006) (discussing consumer privacy disclosures and the protection of consumers’ personal information).

Consumer Advisories

• Consumer Advisory, “Gift Cards: OCC Provides Holiday Tips for Consumers” (November 28, 2006).

• Public Service Announcement, “Gift Card Tips for Holiday Shoppers” (print, script, and .mp3 formats).

• Interagency Brochure, “Interest-Only Mortgage Payments and Payment-Option ARMs – Are They for You?” (October 18, 2006). Other Public Communications

• Community Developments Online Newsletter, “Minority-Owned Banks – Making

a Difference in Their Communities” (December 21, 2007). • Community Developments: Insights, “Reaching Minority Markets: Community

Bank Strategies” (November 2006). • Community Developments: Investments, “2005 CRA Revisions: How Banks and

Examiners Are Implementing the New Rules” (September 1, 2006). • Community Developments Newsletter, “Homeownership: Preserving the

American Dream” (Spring 2006). 2005: Speeches and Testimony

• John C. Dugan, Comptroller of the Currency, Remarks before the Consumer Federation of America (December 1, 2005) (discussing negative amortization and its increasing prominence in retail credit products).

• John C. Dugan, Comptroller of the Currency, Remarks before the American Bankers Association (September 26, 2005) (discussing safety and soundness initiatives, as well as the new Home Mortgage Disclosure Act reporting requirements and anti-money laundering).

• Julie L. Williams, Chief Counsel and First Senior Deputy Comptroller, Testimony before the Subcommittee on Financial Institutions and Consumer Credit of the

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Committee on Financial Services of the U.S. House of Representatives (September 22, 2005) (discussing regulatory burden reduction and increasing the effectiveness of consumer disclosures).

• Julie L. Williams, Chief Counsel and First Senior Deputy Comptroller, Remarks before the Canisius College School of Business (September 14, 2005) (discussing nontraditional mortgage products).

• Julie L. Williams, Acting Comptroller of the Currency, Testimony before the Committee on Banking, Housing, and Urban Affairs of the U.S. Senate (June 21, 2005) (discussing regulatory burden reduction and increasing the effectiveness of consumer disclosures).

• Julie L. Williams, Acting Comptroller of the Currency, Testimony before the Subcommittee on Financial Institutions and Consumer Credit of the Committee on Financial Services of the U.S. House of Representatives (June 9, 2005) (discussing regulatory burden reduction and increasing the effectiveness of consumer disclosures).

• Julie L. Williams, Acting Comptroller of the Currency, Testimony before the Committee on Banking, Housing, and Urban Affairs of the U.S. Senate (May 17, 2005) (discussing the OCC’s perspectives on improving credit card disclosures).

• Julie L. Williams, Acting Comptroller of the Currency, Remarks before an EGRPRA Outreach Meeting (May 12, 2005) (discussing regulatory burden reduction and increasing the effectiveness of consumer disclosures).

• Julie L. Williams, Acting Comptroller of the Currency, Remarks before the Regional Interagency Committee (May 3, 2005) (discussing the need for mortgage delinquency intervention programs to prevent foreclosures).

• Julie L. Williams, Acting Comptroller of the Currency, Remarks before the Independent Community Bankers of America (March 11, 2005) (discussing the effectiveness and burden of consumer disclosures and a recent Community Reinvestment Act proposal).

• Julie L. Williams, Acting Comptroller of the Currency, Remarks before Women in Housing and Finance and the Exchequer Club (January 12, 2005) (discussing the use of disclosures to accomplish consumer protection objectives).

Consumer Advisories

• Consumer Advisory, “Writing a Check: Understanding Your Rights” (August 2, 2005).

• Brochure, “Assistance for Customers of National Banks” (June 6, 2005) (explaining the function of the OCC’s Customer Assistance Group and how to contact them).

• Public Service Announcement, “Hurricane Victims: Contact Your Lender” (script and .mp3 formats). Other Public Communications

• News Release 2005-105, “OCC Encourages National Banks to Work with

Customers Affected by Hurricane Wilma” (October 24, 2005).

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• News Release 2005-94, “OCC Encourages National Banks to Work with Customers Affected by Hurricane Rita” (September 21, 2005).

• News Release 2005-89, “OCC Encourages National Banks to Work with Customers Affected by Hurricane Ophelia” (September 15, 2005).

• News Release 2005-87, “Agencies Encourage Insured Depository Institutions to Assist Displaced Customers” (September 2, 2005).

• Community Developments Online Newsletter, “Using the New HMDA Data to Expand Home Mortgage Lending Opportunities” (August 29, 2005).

• News Release 2005-83, “OCC Encourages National Banks to Work with Customers Affected by Hurricane Katrina” (August 29, 2005).

• News Release 2005-67, “OCC Encourages National Banks to Work with Customers Affected by Hurricane Dennis” (July 11, 2005).

• Community Developments: Insights, “Payroll Cards: An Innovative Product for Reaching the Unbanked and Underbanked” (June 2005).

• Letter from Julie L. Williams, Acting Comptroller of the Currency, to Jennifer J. Johnson, Secretary, Board of Governors of the Federal Reserve System (April 7, 2005) (commenting on issues relating to open-end credit under the Truth in Lending Act and Regulation Z).5

• Community Developments: Insights, “Individual Development Accounts: An Asset Building Product for Lower-Income Consumers” (March 2, 2005).

2004:

Speeches and Testimony • John D. Hawke, Jr., Comptroller of the Currency, Remarks before the American

Bankers Association (October 4, 2004) (discussing challenges faced by the banking community, including more effective consumer disclosures and avoiding abusive consumer credit products).

• Julie L. Williams, Chief Counsel and First Senior Deputy Comptroller, Remarks before the Consumer Bankers Association (September 29, 2004) (discussing changes to the reporting requirements implementing the Home Mortgage Disclosure Act).

• Julie L. Williams, Chief Counsel and First Senior Deputy Comptroller, Remarks before the Cleveland Neighborhood Housing Services (June 15, 2004) (discussing the need to combat predatory lending).

Consumer Advisories • Consumer Advisory, “Gift Cards: OCC Provides Holiday Tips for Consumers”

(December 7, 2004). • Public Service Announcement, “What You Need to Know about Gift Cards”

(script and .mp3 formats).

5 Letter available upon request.

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• Interagency Consumer Brochure, “Protecting Yourself from Overdraft and Bounced-Check Fees” (October 14, 2004).

• Interagency Consumer Brochure, “Warning: Internet Pirates Are Trying to Steal Your Personal Financial Information; Here’s the Good News: You Have the Power to Stop Them” (September 8, 2005) (discussing phishing).

• Interagency Consumer Brochure, “Putting Your Home on the Loan Line is Risky Business” (April 13, 2004) (in Spanish).

Other Public Communications • Community Developments Online Newsletter, “The Power of Plastic: How Banks

are Using Technology to Reach the Unbanked” (October 6, 2004). • News Release 2004-85, “OCC Encourages National Banks to Work with

Customers Affected by Hurricane Ivan” (September 16, 2004). • Community Developments: Insights, “Remittance: A Gateway to Banking for

Unbanked Immigrants” (September 15, 2004). • News Release 2004-76, “OCC Encourages National Banks to Work with

Customers Affected by Hurricane Francis” (September 7, 2004). • News Release 2004-68, “OCC Encourages National Banks to Work with

Customers Affected by Hurricanes Bonnie and Charley” (August 17, 2004). 2003: Speeches and Testimony

• Mark A Nishan, Chief of Staff, Remarks before the Midwest National Bank Conference (October 9, 2003) (discussing the need to instill in all bank employees a dedication to the highest standards of fairness and ethical dealing).

• John D. Hawke, Jr., Comptroller of the Currency, Remarks before the American Bankers Association (September 22, 2003) (discussing the need for bankers to be proactive to prevent abusive practices in the marketplace).

• John D. Hawke, Jr., Comptroller of the Currency, Remarks before the Federalist Society (July 24, 2003) (discussing OCC’s approach to preventing abusive lending practices).

• Julie L. Williams, Chief Counsel and First Senior Deputy Comptroller, Remarks before the Risk Management Association’s Retail Risk Management Conference (June 3, 2003) (discussing interagency credit card account management guidance and importance of considering fairness to customers when developing fee-generating banking products).

• John D. Hawke, Jr., Comptroller of the Currency, Remarks before the Consumer Bankers Association (April 15, 2003) (discussing the need for banks to market to increasingly diverse communities).

• John D. Hawke, Jr., Comptroller of the Currency, Remarks before the Independent Community Bankers of America (March 4, 2003) (discussing need for a study on costs of compliance burden and effectiveness of consumer disclosures).

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Consumer Advisories

• Interagency Consumer Brochure, “Putting Your Home on the Loan Line is Risky

Business” (October 7, 2003).

Other Public Communications

• News Release 2003-76, “OCC Encourages National Banks to Work with Customers Affected by Hurricane Isabel” (September 23, 2003).

• John D. Hawke, Jr., Comptroller of the Currency, Letter to James Gilleran, Chairman, Federal Financial Institutions Examination Council (July 2, 2003) (urging that the FFIEC member agencies consider jointly issuing supervisory guidance to address overdraft protection programs).6

• Community Developments Newsletter, “Financing Housing in Rural America” (June 11, 2003).

2002: Speeches and Testimony

• Julie L. Williams, Chief Counsel and First Senior Deputy Comptroller, Remarks before the Local Initiatives Support Corporation’s Annual Staff Conference (April 10, 2002) (discussing the important role of community development corporations and their beneficial relationships with banks).

• John D. Hawke, Jr., Comptroller of the Currency, Remarks before the Consumer Bankers Association (April 8, 2002) (discussing the benefits of financial literacy programs).

• Julie L. Williams, Chief Counsel and First Senior Deputy Comptroller, Remarks before the Mid-Atlantic Bank Compliance Conference (March 22, 2002) (discussing the importance of avoiding unfair and deceptive marketing practices).

• John D. Hawke, Jr., Comptroller of the Currency, Remarks before the American Bankers Association National Community and Economic Development Conference (March 18, 2002) (discussing opportunities to expand traditional banking services and to bring underbanked, low-income customers into the mainstream of the banking system).

Consumer Advisories

• Interagency Consumer Brochure, “Privacy Choices for Your Personal Financial

Information” (February 6, 2002).

6 Letter available upon request.

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2001: Speeches and Testimony

• Julie L. Williams, Chief Counsel and First Senior Deputy Comptroller, Remarks before the McAuley Institute’s 7th National Women and Housing Conference (November 9, 2001) (discussing challenges faced by women in building and maintaining assets).

• Julie L. Williams, Chief Counsel and First Senior Deputy Comptroller, Remarks before the Consumer Bankers Association (May 21, 2001) (discussing the adaptation of the Community Reinvestment Act regulation to a changing banking system).

• Julie L. Williams, Chief Counsel and First Senior Deputy Comptroller, Remarks before the American Banker’s 2nd Account Aggregation Conference (April 23, 2001) (discussing banks’ use of third-party account aggregators and the need for the protection of consumers’ nonpublic personal financial information).

• John D. Hawke, Jr., Comptroller of the Currency, Remarks before the National Community Reinvestment Coalition (March 6, 2001) (discussing the challenges of reaching the unbanked).

• John D. Hawke, Jr., Comptroller of the Currency, Remarks before the National Association of Affordable Housing Lenders (March 1, 2001) (discussing the current challenges involving community development projects).

Consumer Advisories

• Consumer Brochure, “How to Avoid Becoming a Victim of Identity Theft” (April 30, 2001).

• Interagency Consumer Brochure, “Looking for the Best Mortgage: Shop, Compare, Negotiate” (March 8, 2001) (in Spanish).

Other Public Communications

• Community Developments Newsletter, “Banking in Indian Country” (November

30, 2001). • News Release 2001-88, “OCC Supports Efforts of National Banks to Aid in

[9/11] Recovery Efforts” (October 5, 2001). • News Release 2001-79, “OCC Encourages National Banks to Work with

Customers Affected by Terrorist Attacks” (September 12, 2001). • Community Developments Newsletter, “Growing Diverse Banking Markets:

Going Beyond Traditional Measures” (August 8, 2001). • Letter from Daniel P. Stipano, Deputy Chief Counsel, to Third-Party Overdraft

Protection Program Provider (August 3, 2001) (expressing a number of concerns about the overdraft protection program).7

7 Letter available at http://www.occ.treas.gov/interp/sep01/int914.pdf.

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• News Release 2001-53, “OCC Encourages National Banks to Work with Customers Affected by Floods in Houston Area” (June 11, 2001).

• Letter from Julie L. Williams, Chief Counsel, and William F. Kroener, III, General Counsel, FDIC, to Virgil Mattingly, General Counsel, Board of Governors of the Federal Reserve System (March 29, 2001) (urging the Board to amend Regulation AA to add a general prohibition on unfair or deceptive practices in violation of the FTC Act and to expressly address unfair or deceptive credit card marketing practices).8

2000: Speeches and Testimony

• Julie L. Williams, Chief Counsel and First Senior Deputy Comptroller, Testimony before the Subcommittee on Finance and Hazardous Materials of the Committee on Commerce of the U.S. House of Representatives (July 20, 2000) (discussing the status of the OCC’s insurance consumer protection regulations).

• John D. Hawke, Jr., Comptroller of the Currency, Remarks before the Stonier Graduate School of Banking (June 20, 2000) (discussing an emphasis on sound banking practices, including customer service and the protection of consumers’ nonpublic financial information).

• Julie L. Williams, Chief Counsel and First Senior Deputy Comptroller, Remarks before the Robert Morris Associates/Consumer Bankers Association 5th Annual Consumer Risk Management Conference (June 5, 2000) (discussing action to combat predatory lending).

• John D. Hawke, Jr., Comptroller of the Currency, Statement before the Committee on Banking and Financial Services of the U.S. House of Representatives (May 24, 2000) (discussing issues regarding predatory lending practices in the consumer credit industry).

• John D. Hawke, Jr., Comptroller of the Currency, Remarks before the National Community Reinvestment Coalition (March 21, 2000) (discussing action to combat predatory lending).

Other Public Communications

• Joint Statement by John D. Hawke, Jr., Comptroller of the Currency, and Ellen Seidman, Director, Office of Thrift Supervision (November 27, 2000) (addressing title loans and payday loans).

• Community Developments Newsletter, “Focus on Retail Financial Services to Underserved Communities” (September 28, 2000).

• News Release 2000-34, “OCC Encourages National Banks to Work with Customers Affected by Fires in New Mexico” (May 15, 2000).

8 Letter available upon request.

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1999: Speeches and Testimony

• John D. Hawke, Jr., Comptroller of the Currency, Remarks before the Consumer Federation of America (December 2, 1999) (discussing Graham-Leach-Bliley Act’s consumer benefits, including customer privacy, as well as combating predatory lending and excessive fees).

• Julie L. Williams, Chief Counsel and First Senior Deputy Comptroller, Remarks before the California Bankers Association Regulatory Compliance Conference (October 6, 1999) (discussing the need for banks to integrate “compliance” with a broader strategy of customer relations and customer service).

• John D. Hawke, Jr., Comptroller of the Currency, Testimony before the Subcommittee on Financial Institutions and Consumer Credit of the Committee on Banking and Financial Services of the U.S. House of Representatives (July 21, 1999) (discussing the importance of maintaining the privacy of consumers’ nonpublic financial information).

• John D. Hawke, Jr., Comptroller of the Currency, Remarks before the American Bankers Association Regulatory Compliance Conference (June 28, 1999) (discussing the OCC’s risk-focused approach to compliance supervision).

• Julie L. Williams, Chief Counsel and First Senior Deputy Comptroller, Testimony before the Subcommittee on Oversight and Investigations of the Committee on Commerce of the U.S. House of Representatives (June 25, 1999) (discussing the importance of accurate disclosure and fair treatment for customers of bank-affiliated brokers).

• Julie L. Williams, Chief Counsel and First Senior Deputy Comptroller, Remarks before the Financial Institutions Insurance Association Regulatory and Compliance Conference (June 22, 1999) (discussing consumer privacy concerns).

• John D. Hawke, Jr., Comptroller of the Currency, Remarks before a Conference Sponsored by the Consumer Bankers Association and Robert Morris Associates (June 7, 1999) (discussing need to improve customer service standards and end abusive practices).

• John D. Hawke, Jr., Comptroller of the Currency, Remarks before the Neighborhood Housing Services of New York (May 5, 1999) (discussing success of the Community Reinvestment Act and criticizing lenders who do not report borrower payment histories to credit bureaus).

• John D. Hawke, Jr., Comptroller of the Currency, Remarks before the Summit on Contingency Planning and Customer Awareness of the President’s Council on Year 2000 Conversion (April 15, 1999) (discussing the importance of communication with consumers on Year-2000 issues).

• John D. Hawke, Jr., Comptroller of the Currency, Remarks before the National Community Reinvestment Coalition (March 19, 1999) (discussing the success of the Community Reinvestment Act and the importance of information and education in reaching the unbanked).

• Julie L. Williams, Chief Counsel and First Senior Deputy Comptroller, Remarks before the Third Annual Race and Relations Conference of the Louisville and

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Jefferson County Human Relations Commission (January 28, 1999) (discussing successes of the Community Reinvestment Act and the possibilities for partnerships between bankers and communities).

Consumer Advisories

• Consumer Brochure, “Looking for the Best Mortgage: Shop, Compare, Negotiate” (June 17, 1999). Other Public Communications

• News Release 99-82, “OCC Encourages National Banks to Work with Customers

Affected by Hurricane in Eastern U.S.” (September 16, 1999). • News Release 99-3, “OCC Encourages National Banks to Work with Customers

Affected by Storms in Arkansas and Tennessee” (January 25, 1999).

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Appendix E

OCC Consumer Complaint Function

Overview The OCC helps individual customers of national banks primarily through the Customer Assistance Group (CAG). CAG answers questions, offers guidance, and assists consumers in resolving complaints about national banks and their subsidiaries.1 A consumer may obtain assistance from CAG by calling a toll free number, Monday through Friday, 7:00 a.m. to 7:00 p.m. Central Time, or by sending an email to [email protected]. CAG has 67 full-time employees dedicated to handling consumer complaints. Specialists in CAG have banking backgrounds, and include former bank examiners and compliance officers. Many are certified regulatory compliance managers, having achieved the professional certification issued by an affiliate of the American Bankers Association. OCC personnel, including attorneys in the OCC Law Department, regularly assist CAG staff with more complex issues or problems. Cases involving, for example, allegations of discrimination, predatory lending, or unfair or deceptive practices generally are reviewed by CAG personnel in close consultation with the Law Department. In an effort to make CAG even more efficient, and allocate more of the specialists’ time to substantive work on the complaints, CAG has contracted with a third party to help provide initial complaint processing services by phone. These contracted customer service representatives (CSRs), stationed in Fort Worth, Texas, answer calls to CAG’s toll-free number. The CSRs give only general information, such as informing consumers how to send in a written complaint and referring consumers to information on our website, helpwithmybank.gov. When CAG receives the written complaint, CAG will send the consumer an acknowledgment letter and assign a case number if one was not previously provided. The specialist will research the complaint and contact the bank for a response. The OCC will notify the consumer after the bank or subsidiary responds. The bank or its subsidiary often resolves voluntarily those complaints caused by bank errors or misunderstandings. The OCC does not require any particular complaint form to be used, but we do provide a complaint form on our public website for consumers’ convenience. The form, and other information about the OCC’s complaint process, is available in both English and Spanish at http://www.occ.treas.gov/customer.htm. Earlier this year, CAG’s web site was enhanced so that consumers can file their complaints on-line. 1 The Federal Trade Commission Act requires the OCC, the Board, the FDIC, the OTS, and the NCUA to establish a consumer affairs division to receive and take appropriate action on complaints of unfair or deceptive acts or practices by institutions subject to their jurisdiction. 15 U.S.C. § 57a(f)(1).

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Further information about the OCC’s complaint process can be found at:

• OCC, Assistance for Customers of National Banks (2009), http://www.occ.gov/customer.pdf

• OCC, Report of the Ombudsman (2005-2006),

http://www.occ.gov/Ombudsman/2006OmbudsmanReport.pdf

• OCC, Annual Report, Fiscal Year 2008, at pp. 38-39, http://www.occ.gov/annrpt/1-2008AnnualReport.pdf

• Remarks by Comptroller of the Currency John C. Dugan Before the Exchequer

Club and Women in Housing and Finance, January 17, 2007 http://www.occ.gov/ftp/release/2007-4a.pdf

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HelpWithMyBank.gov The OCC created HelpWithMyBank.gov with national bank customers in mind. The Web site was launched in July 2007 and is maintained by CAG with the goal of creating a site that makes it easier for people to get answers and submit concerns about their bank. In 2008, HelpWithMyBank.gov won the award for “best website” from The National Association of Consumer Agency Administrators, an organization with 160 government agency and 50 corporate members that aims to promote consumer education and consumer rights. Since its launch a little more than two years ago, HelpWithMyBank.gov has been accessed nearly 1 million times by consumers seeking information about banking-related matters. And, references to the website have been increasingly dramatically since the site was launched. In the last half of 2007, the website received 123,386 hits. The number of hits climbed to 327,907 in 2008 and to 513,276 thus far in 2009 (through September 28). HelpWithMyBank.gov provides answers to over 250 common banking questions, which are selected based on the thousands of questions that CAG receives each year. The site presents information in straightforward, easy-to-use terms in a simple question-and answer format. The site covers many topics including credit cards, interest rates, check cashing, late payments, and mortgages. In addition to finding answers to specific questions on banking products and services, consumers may file a complaint about a specific bank through the site. HelpWithMyBank.gov makes it easier to contact the OCC, to check if the consumer’s institution is a national bank, to find whom to contact if it is not, and to file complaints regarding national banks. Key features of the site include:

• Frequently asked questions and answers; • Lists of banks and operating subsidiaries supervised by the OCC and information

about whom to contact if the bank is not OCC-supervised; • Information about how to contact the OCC; • A mechanism to file complaints and check their status online if the bank is a

national bank; • Consumer advisories on banking trends and practices; and • A dictionary of banking terms.

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Complaint Volumes and Monetary Compensation to Consumers Complete data regarding CAG complaint volumes and consumer restitution for the period from 1999 through August 2009 are set forth in the chart on the next page. As shown in the chart, CAG has handled approximately 350,000 complaints over the past decade, and consumers have received nearly $70 million in monetary compensation. This monetary compensation does not include other forms of corrective action, such as mortgage modifications, reduced credit card interest rates, or corrected credit bureau reports.

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Customer Assistance Group: Inquiries, Complaints, and Compensation

1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 (First 8 months)

Inquiries 29,261 35,910 41,602 46,495 35,000 41,892 40,983 35,591 43,619 60,481 62,257 Complaints 64,380 42,970 37,643 31,093 37,000 28,100 31,793 27,155 28,316 34,542 43,172 Total 93,641 78,880 79,245 77,588 72,000 69,992 72,776 62,746 66,935 95,023 105,429 Reimbursements To Consumers

$3,171,595

$5,409,750

$4,284,605

$6,608,526

$4,352,564

$5,437,596

$7,643,687

$7,910,050

$8,841,799

$11,497,719

$6,457,731

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Appendix F

Reviews, Audits, and Assessments of OCC Consumer Protection Initiatives

The OCC conducts reviews of its own supervisory activities to ensure that examiners are implementing supervisory guidance and examination policies appropriately and consistently, and to identify best practices or other mechanisms for improving our supervisory processes. These reviews encompass all aspects of bank supervision, including both prudential and consumer protection matters. This quality assurance process is not a centralized agency function, but instead one that is conducted as an integral part of the activities of the supervisory units – Large Bank Supervision (LBS) and Midsize/Community Bank Supervision (MCBS) – themselves. Each unit maintains a summary of, and specific memoranda related to, the work performed with respect to the quality assurance efforts it undertakes. For LBS, the purposes of the quality assurance program are to provide an independent evaluation of compliance with established LBS policies and procedures, to promote consistent application of OCC supervision policies within LBS, to make recommendations for enhancements, and to encourage dissemination of best practices. The quality assurance process for LBS activities utilizes both targeted and ongoing reviews, and covers the full range of supervisory activities, including the establishment of supervisory strategies and the execution of those strategies in safety and soundness, consumer compliance, and other areas. Within MCBS, each deputy comptroller prepares an annual business plan for his or her unit that includes quality assurance activities. MCBS quality assurance programs include real time review of all examination conclusions (in safety and soundness, consumer compliance, and other areas) by both managers within the direct reporting lines of the examiners conducting examinations and managers who comprise supervision review committees established for enforcement actions and other significant matters. MCBS quality assurance processes also include after the fact reviews of supervisory activities by sampling a representative group of institutions and activities within each unit. This work is done by examiners independent of the institutions being reviewed. In addition, horizontal reviews of similarly situated institutions that focus on a particular risk or business activity are conducted, if warranted by relevant risk assessments. These reviews also encompass all facets of the bank’s operation, including safety and soundness and compliance.

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Event Location Topic

2001Hispanic Banking Forum Atlanta, GA Bank initiatives to reach Hispanic customers.Hispanic Banking Forum Philadelphia, PA Bank initiatives to reach Hispanic customers.Banker CRA Roundtable Los Angeles, CA Discussion of Community Reinvestment Act activities.Banker CRA Roundtable San Diego, CA Discussion of Community Reinvestment Act activities.Banker CRA Roundtable Seattle, WA Discussion of Community Reinvestment Act activities.Community Development Project Tour Atlanta, GA Reviewing bank involvement in community development projects in Atlanta.Community Development Project Tour Chicago, IL Reviewing bank involvement in community development projects in Chicago.Banker CRA Roundtable New Orleans, LA Discussion of CDFI Fund programs and how banks can utilize them.Banker CRA Roundtable San Bernardino, CA Discussion of bank financing for community based development organizations.Banker CRA Roundtable Phoenix, AZ Discussion of Community Reinvestment Act activities.Predatory Lending Forum New York, NY Discussion of ways to bring about heavier regulation of non regulated entities originating subprime loans.Banker CRA Roundtable Las Vegas, NV Ways banks can partner with Nevada CDFIs.Banker CRA Roundtable Mesa, AZ Presentation by City of Mesa and tour of community development projects.Banker CRA Roundtable Dallas, TX Discussion of small business financing by CDFIs.Predatory Lending Forum Kansas City, MO Discussion of ways to bring about heavier regulation of non regulated entities originating subprime loans.Banker CRA Roundtable Los Angeles, CA Discussion of financial literacy and Individual Development Accounts.Banker CRA Roundtable Riverside, CA Discussion of financial literacy and Individual Development Accounts.Banker CRA Roundtable Trenton, NJ Discussion of financial literacy and Individual Development Accounts.Banker CRA Roundtable Phoenix, AZ Discussion of affordable housing loan pool by nonprofit housing developers.

2002Banker CRA Roundtable Los Angeles, CA Bank philanthropy partnerships to support affordable housing and community development.Lending Avenues for Latino Immigrants Kansas City, MO Discussion of best practices for providing financial services to unbanked immigrants.Banker CRA Roundtable Phoenix, AZ Discussion of bank financing for redevelopment of Brownfields.Banker CRA Roundtable Los Angeles, CA Discussion of bank involvement in the Los Angeles Housing Trust Fund financing affordable housing.Banker CRA Roundtable Carson City, NV Discussion of bank involvement in small business lending initiatives.Native American Banking Forum Washington, DC Discussion of bank provision of financial services in Indian Country.Hispanic Banking Forum Chicago, IL Bank initiatives to reach Hispanic customers.Community and Economic Development Conference Baltimore, MD National Conference reviewing a range of community development and finance initiatives.Financial Literacy Conference Boston, MA Bank partnerships to promote financial literacy.Banker CRA Roundtable Phoenix, AZ Discussion of Community Reinvestment Act issues.Unbanked Forum Los Angeles, CA Discussion of the needs of the unbanked in the Los Angeles area.Banker CRA Roundtable Los Angeles, CA Southern California economic overview and CRA discussion.Banker CRA Roundtable San Diego, CA Southern California economic overview and CRA discussion.Banker CRA Roundtable Sacramento, CA Environmental restoration, financial literacy, and Individual Development Accounts.Banker CRA Roundtable Dallas, TX Discussion of Community Reinvestment Act activities.National Community Reinvestment Conference Oakland, CA Biennial conference focused on community development lending and investments.

2003Banker CRA Roundtable Los Angeles, CA Discussion of New Markets Tax Credits and public welfare investments.Banker CRA Roundtable Phoenix, AZ Discussion of Native American financial services issues.Financing Faith Based Organizations San Bernardino, CA Discussion of bank initiatives financing faith based community development organizations.Financial Literacy Conference Fresno, CA Financial literacy initiatives focused on Hispanic consumers.Banker CRA Roundtable Los Angeles, CA Gap financing for community development projects.Minority Small Business Forum Los Angeles, CA Bank financing for minority small businesses.Banker CRA Roundtable Phoenix, AZ Discussion of bank initiatives leveraging the Earned Income Tax Credit.Banker CRA Roundtable Dallas, TX Community development opportunities in the Dallas/Ft. Worth area.Banker CRA Roundtable New Orleans, LA Historic preservation finance.Banker CRA Roundtable Houston, TX Discussion of Community Reinvestment Act activities.Banker CRA Roundtable Dallas, TX Discussion of Community Reinvestment Act activities.Banker CRA Roundtable New Orleans, LA Discussion of community development investment opportunities for banks.Financial Literacy Conference Boston, MA Bank/community partnerships to promote financial literacy.Ohio Policy Summit Cleveland, OH Review of the influence of market-based theory on community development policies and programs.Rural Economic Development Lending Opportunities Washington, DC Telephone and web seminar reviewing use of government programs to finance rural economic development.

OCC Sponsored/Co-Sponsored Consumer/Community Development Conferences, Seminars, Roundtables, and ForumsJanuary 1, 2001 - September 30, 2009

1

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2004Ohio Policy Summit Cleveland, OH Wealth building strategies for low income individuals.National Community Reinvestment Conference Los Angeles, CA Biennial conference focused on community development lending and investments.Banker CRA Roundtable Denver, CO Discussion of financing for environmentally contaminated properties.Banker CRA Roundtable Las Vegas, NV Discussion of Community Reinvestment Act activities.Banker CRA Roundtable Los Angeles, CA Discussion of Community Reinvestment Act activities.Banker CRA Roundtable San Diego, CA Discussion of Community Reinvestment Act activities.Banker CRA Roundtable Phoenix, AZ New markets tax credit and microenterprise financing.Banker CRA Roundtable Los Angeles, CA New markets tax credits.Banker CRA Roundtable New Orleans, LA Low income housing tax credits.Banker CRA Roundtable Dallas, TX Discussion of financing minority businesses.Banker CRA Roundtable Jacksonville, FL Financial literacy. Banker CRA Roundtable Dallas, TX Update on HMDA, HOPEA, and RESPA rules.Banker CRA Roundtable Dallas, TX SBA small business financing programs.Banker CRA Roundtable Knoxville, TN Payroll cards and microlending programs.Banker CRA Roundtable St. Petersburg, FL Payroll cards.Multibank Community Development Corporations Urbana, IL Formation and operation of multibank CDCs.Financing Minority Businesses Washington, DC Telephone and web seminar in financing minority businesses. 2005Bankers CRA Roundtable Atlanta, GA Financial literacy and the Get Checking Program.Bankers CRA Roundtable Knoxville, TN Discussion of FHLB Affordable Housing Program.Bankers CRA Roundtable Dallas, TX Discussion of FHLB Affordable Housing Program.Unbanked and Immigrants Market Conference Houston, TX Products and initiatives to reach unbanked populations.Banker CRA Roundtable Birmingham, AL Opportunities for banks to help consumers and businesses affected by the Gulf Coast hurricanes.Banker CRA Roundtable San Francisco, CA Opportunities for bank lending to nonprofits with equity equivalents.Banker CRA Roundtable Las Vegas, NV Discussion of flood insurance and USDA Rural Development Lending by banks.New England Consumer Advisory Council Boston, MA Discussion of issues surrounding alternative mortgage products.Banker CRA Roundtable Los Angeles, CA Discussion of new initiative to finance facilities housing the homeless in Los Angeles.Banker CRA Roundtable San Diego, CA Discussion of 2005 changes to HMDA and CRA.Bankers CRA Roundtable New Orleans, LA Community wealth building.Ohio Policy Summit Cleveland, OH Wealth building strategies for low income individuals.Bankers CRA Roundtable Los Angeles, CA FACT Act and Check 21.Bankers CRA Roundtable New Orleans, LA FACT Act and Check 21.Bankers CRA Roundtable Las Vegas, NV Financing for nonprofit community development organizations.Bankers CRA Roundtable Los Angeles, CA New markets tax credits and low income housing tax credits.Bankers CRA Roundtable Fresno, CA Financing for nonprofit community development organizations.Bankers CRA Roundtable San Bernardino, CA Financing for nonprofit community development organizations.Bankers CRA Roundtable Mobile, AL Financial literacy and the Get Checking Program.Bankers CRA Roundtable Memphis, TN Banking underserved communities.Bankers CRA Roundtable Dallas, TX Meeting financial services needs of Gulf Coast evacuees living in Dallas/Ft. Worth area.Bankers CRA Roundtable Salt Lake City, UT Individual development accounts.Home Mortgage Disclosure Act Washington, DC Telephone and web seminar on revised HMDA rules.Community Development Project Tour Pittsburgh, PA Reviewing bank involvement in community development projects in Pittsburgh.

2006Banker CRA Roundtable Mobile, AL Discussion of small business revolving loans and new credit card rules.Banker CRA Roundtable New Orleans, LA Discussion of the need for counseling in conjunction with new alternative mortgage products.New England Consumer Advisory Council Conference Boston, MA Discussion of alternative mortgage product guidance and HMDA pricing data.Banker CRA Roundtable Phoenix, AZ Discussion of leveraging resources and meeting community development needs in Arizona.Banker CRA Roundtable Salt Lake City, UT Discussion of 2005 changes to HMDA and CRA.Banker CRA Roundtable San Francisco, CA Discussion of comprehensive community development strategies.National Community Reinvestment Conference Henderson, NV Biennial conference focused on community development lending and investments.Banker CRA Roundtable Atlanta, GA Discussion of low income housing tax credit investments.Banker CRA Roundtable Dallas, TX Discussion of community development investment opportunities in Texas.Gulf Coast Bankers Conference New Orleans, LA Discussion of issues faced by banks in the Gulf Coast "post Katrina" and opportunities for partnerships with out of region banks.

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Banker CRA Roundtable Salt Lake City, UT Discussion of consumer compliance regulatory issues and "Examiner Clinic".Making Business Sense of Serving the Unbanked Chicago, IL Serving immigrant communities, business benefits of serving the unbanked, reaching young consumers, and financial education.Serving the Unbanked Immigrant Market Edinburg, TX Unbanked immigrant communities and on the Mexican Border, Earned Income Tax Credit by unbanked, financial institutions role in financial literacy.Banker CRA Roundtable Phoenix, AZ New banker's collaborative to help meet the needs of community development nonprofits in Arizona.Banker CRA Roundtable Dallas, TX Discussion of new CRA provisions.Banker CRA Roundtable Reno, NV Bus tour of community development needs in Reno.Banker CRA Roundtable San Diego, CA Discussion of the economic climate in San Diego.Banker CRA Roundtable Atlanta, GA Discussion of new products provided by the SBA to assist small businesses.Banker CRA Roundtable El Paso, TX Training on the new CRA provisions.Banker CRA Roundtable San Francisco, CA Bank supplier diversity initiatives.Banker CRA Roundtable Tucson, AZ Discussion of financial literacy and Get Checking Program.Banker CRA Training Pittsburgh, PA New CRA rules and affordable housing lending.Banker CRA Roundtable El Paso, TX Discussion of increasing investment in LMI communities in the El Paso and Southern New Mexico markets.Banker CRA Roundtable New Orleans, LA Rebuilding efforts and opportunities for bank collaboration with government efforts.Banker CRA Roundtable Detroit, MI Discussion of the economic outlook in Detroit.Banker CRA Roundtable Salt Lake City, UT Discussion of asset accumulation issues, including the Earned Income Tax Credit and Individual Development Accounts.Exploring Opportunities for the Unbanked Fresno, CA Reaching the large unbanked population in the Central Valley of California.Banker CRA Roundtable Knoxville, TN Providing an overview of the changes to CRA, tax credits, and foreclosure prevention.Banker CRA Roundtable Las Vegas, NV Discussion of asset building initiatives banks can support.Banker CRA Roundtable Los Angeles, CA Discussion of bank support for community development investments.Banker CRA Roundtable San Diego, CA Discussion of bank support for community development investments and the CDFI rating systems "CARS".New England Consumer Advisory Council Conference Boston, MA Discussion of fraudulent activities affecting the financial services industry and well as hot topics in consumer protection.Banker CRA Roundtable Phoenix, AZ New affordable housing finance initiatives.The New CRA Perspective Washington, DC Telephone and web seminar on revised CRA regulations.Community Development Project Tour Chicago, IL Reviewing bank involvement in community development projects in Chicago.Community Development Project Tour Washington, DC Reviewing bank involvement in community development projects in Washington, D.C.

2007Working Together to Move People Ahead Seattle, WA Large and small institutional models for reaching the unbanked, role of community organizations in reaching the unbanked.Reaching Unbanked People New York, NY Reaching unbanked people, participation in the financial mainstream, asset building and financial access, alternative financial institutions.Bankers CRA Roundtable Baton Rouge, LA Discussion of small business development as part of the Gulf Coast rebuilding efforts.Bankers CRA Roundtable Dallas, TX Discussion of financial literacy initiatives.Bankers CRA Roundtable Phoenix, AZ Discussion of Community Reinvestment Act activities.Bankers CRA Roundtable Jacksonville, FL Discussion of bank participation in bank affordable housing finance programs.Bankers CRA Roundtable Dallas, TX Affordable housing initiatives in the Dallas/Ft. Worth area.Bankers CRA Roundtable Chicago, IL Discussion of bank lending to nonprofits and mortgage lending to recent immigrants.Bankers CRA Roundtable Las Vegas, NV Discussion of Community Reinvestment Act activities.Bankers CRA Roundtable New Orleans, LA To provide updates on Gulf Coast rebuilding efforts and future opportunities for bank involvement.Bankers CRA Roundtable Salt Lake City, UT Discussion of Community Reinvestment Act activities.Homeownership Preservation Summit San Francisco, CA Discussion of foreclosure prevention initiatives in San Francisco, CA.Non Traditional Mortgage Forum Pittsburgh, PA Discussion of the regulatory environment for nontraditional mortgages, the secondary market, and related financial literacy initiatives.Interagency CRA Training Knoxville, TN CRA training for community banks.Homeownership Preservation Summit Fresno, CA Discussion of foreclosure prevention initiatives in Fresno, CA.Bankers CRA Roundtable Birmingham, AL Discussion of foreclosure trends, Individual Development Account Programs, and the nontraditional mortgage guidance.Banking the Immigrant Market Workshop Chicago, IL To discuss topics related to providing financial services for immigrants.Ohio Policy Summit Cleveland, OH Discussion of nontraditional mortgages, foreclosures, small city revitalization, and CRA in urban and rural areas.Homeownership Preservation Summit Los Angeles, CA Discussion of foreclosure prevention initiatives in Los Angeles, CA.Homeownership Preservation Summit Phoenix, AZ Discussion of foreclosure prevention initiatives in Phoenix, AZ.Homeownership Preservation Summit San Diego, CA Discussion of foreclosure prevention initiatives in San Diego, CA.Homeownership Preservation Summit Las Vegas, NV Discussion of foreclosure prevention initiatives in Las Vegas, NV.Bankers CRA Roundtable Albuquerque, NM Discussion of Community Reinvestment Act activities.

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Bankers CRA Roundtable Denver, CO Discussion of efforts to support small business and affordable housing.Bankers CRA Roundtable Los Angeles, CA Discussion of Community Reinvestment Act activities.Homeownership Preservation Summit New York, NY Discussion of foreclosure prevention initiatives in New York.SBA 504 Program Washington, DC Telephone and web seminar on using SBA's CDC program.Community Development Project Tour Los Angeles, CA Reviewing bank involvement in community development projects in Los Angeles.Regional Interagency Council Breakfast New York, NY Discussion of stated income lending.

2008 Bankers CRA Roundtable Salt Lake City, UT Tour of community development projects that support homeless families and immigrant populations.National Community Reinvestment Conference San Francisco, CA Biennial conference focused on community development lending and investments.Community Development Project Tour New York, NY Reviewing bank involvement in community development projects in New York.Community Development Project Tour New Orleans, LA Reviewing bank involvement in projects supporting the rebuilding of New Orleans.Bankers CRA Roundtable Los Angeles, CA Overview of the mechanics of Low Income Housing Tax Credit investmentsBankers CRA Roundtable Birmingham, AL Overview of the mechanics of Low Income Housing Tax Credit investmentsBankers CRA Roundtable Casper, WY State supported first time homebuyer program and Wyoming Business Council's small business lending partnership program.Interagency CRA Training Columbia, SC CRA training for community banks.Bankers CRA Roundtable Los Angeles, CA Investing in "equity equivalents" issued by nonprofit CDFIsAddressing the Negative Impacts of Foreclosure Los Angeles, CA Review successful REO disposition and acquisition approaches as well as rehab funding sources and property management issuesNew England Interagency CRA Officer's Workshop Boston, MA CRA training for community banks.New England Consumer Advisory Council Boston, MA Discussion of foreclosure relief programs.Regional Interagency Council Breakfast New York, NY Discussion of mortgage foreclosure issues.Bankers CRA Roundtable Salt Lake City, UT Discussion of mortgage foreclosure issues.Bankers CRA Roundtable Las Vegas, NV Asset building programs for low income individuals.Improving Outcomes at Foreclosure San Francisco, CA Discussion related to servicing challenges for qualifying borrowers for mortgage workouts.Bankers CRA Roundtable Albuquerque, NM Development of affordable housing on Indian reservations.Bankers CRA Roundtable San Diego, CA Discussion of Community Reinvestment Act activities.Bankers CRA Roundtable Phoenix, AZ Asset building programs for low income individuals.Interagency CRA Training Little Rock, AR CRA training for community banks.Interagency CRA Training Jackson, MS CRA training for community banks.Interagency CRA Training Baton Rouge, LA Financing for non conventional redevelopment projects.Interagency CRA Training Orlando, FL CRA training for community banks.Bankers CRA Roundtable New Orleans, LA Discussion of New Markets Tax Credits.Loan Servicers Forum Los Angeles, CA Review successful REO disposition and acquisition approaches as well as rehab funding sources and property management issues.Compliance Officers Training Chicago, IL Putting together a community development strategy.Bankers CRA Roundtable Las Vegas, NV Financing for nonprofit community development organizations.Bankers CRA Roundtable Los Angeles, CA Community development lending, investment, and service opportunities.Bankers CRA Roundtable Phoenix, AZ Discussion of proposed revisions to CRA.Ohio Policy Summit Cleveland, OH Discussion of community stabilization activities to address high foreclosures.New England Consumer Advisory Council Boston, MA Discussion of foreclosure relief programs.Bankers CRA Roundtable Dallas, TX Discussion about identifying and reducing mortgage loan fraud.Bankers CRA Roundtable Jackson, MS Discussion of foreclosure relief programs.Bankers CRA Roundtable Shreveport, LA CRA training for community banks.New York City Foreclosure Summit New York, NY Discussion of foreclosure relief programs and addressing the impacts of high foreclosures on neighborhoods.Bankers CRA Roundtable Dallas, TX Financing multifamily affordable housing.Interagency CRA Training San Antonio, TX CRA training for community banks.Fair Lending Conference New Orleans, LA Ensuring fair lending in financial institutions.Real Estate Owned Symposium San Diego, CA Review successful REO disposition and acquisition approaches as well as rehab funding sources and property management issues.Bankers CRA Roundtable Los Angeles, CA Financial literacy initiatives.Bankers CRA Roundtable Salt Lake City, UT Statewide community development initiatives.Bankers CRA Roundtable San Diego, CA Financial literacy initiatives.Bankers CRA Roundtable Kansas City, MO Small dollar consumer loan products.

2009Low Income Housing Tax Credits Simplified Richmond, VA Overview of the mechanics of Low Income Housing Tax Credit investments.Addressing the Main Street Credit Crunch York, PA Review of SBA lending programs.Addressing the Main Street Credit Crunch Williamsport, PA Review of SBA lending programs.Addressing the Main Street Credit Crunch Scranton, PA Review of SBA lending programs.Interagency CRA Training Columbus, OH CRA training for community banks.Interagency CRA Training Lubbock, TX CRA training for community banks.Low Income Housing Tax Credits Simplified Indianapolis, IN Overview of the mechanics of Low Income Housing Tax Credit investments.Foreclosure Prevention and Mitigation Baton Rouge, LA Discussion of foreclosure relief programs and addressing the impacts of high foreclosures on neighborhoods.

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Interagency CRA Training Memphis, TN CRA training for community banks.Bankers CRA Roundtable Dallas, TX Affordable housing financing initiatives.Neighborhood Stabilization Through REO Transfers Los Angeles, CA Review successful REO disposition and acquisition approaches as well as rehab funding sources and property management issues.Bankers CRA Roundtable San Diego, CA Review of new CRA Q's and A's.Bankers CRA Roundtable Los Angeles, CA Review of new CRA Q's and A's.Bankers CRA Roundtable Kansas City, MO Review of public facilities financing program.Bankers CRA Roundtable Cheyenne, WY Affordable housing financing initiatives.Bankers CRA Roundtable Las Vegas, NV Review of new CRA Q's and A's.Bankers CRA Roundtable Irvine, CA Discussion of CRA.Bankers CRA Roundtable Denver, CO Affordable housing financing initiatives.Small Business Financing Initiatives in the Recovery Act Washington, DC Telephone web seminar on using SBA program changes in the Recovery Act.Community Development Tour Dallas, TX Reviewing bank involvement in community development projects in Dallas.Interagency CRA Training Denver, CO CRA training for community banks.Low Income Housing Tax Credits Simplified Philadelphia, PA Overview of the mechanics of Low Income Housing Tax Credit investments.Interagency CRA Training Louisville, KY CRA training for community banks.Bankers CRA Roundtable Lincoln, NE Discussion of CDFI lending initiatives.Atlanta Regional Housing Forum Atlanta, GA Affordable housing financing initiatives.CRA In the New Lending Environment Houston, TX CRA lending opportunities for banks in a down economy.Bankers CRA Roundtable New Orleans, LA HUD's Neighborhood Stabilization Program.HOPE Now Borrower's Outreach Atlanta, GA Outreach to borrowers in need of mortgage workout assistance.HOPE Now Borrower's Outreach Miami, FL Outreach to borrowers in need of mortgage workout assistance.Bankers CRA Roundtable Mobile, AL HUD's Neighborhood Stabilization Program.Community Stabilization in Florida Washington, DC Telephone seminar for banks on participating in the HUD Neighborhood Stabilization Program.Credit Card Forum New York, NY Review of the new credit card rules.CRA In the New Lending Environment Chicago, IL CRA lending opportunities for banks in a down economy.Credit Card Forum Pittsburgh, PH Review of the new credit card rules.Community Banks & Outlook for Residential Lending Detroit, MI Affordable housing financing initiatives.

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