On Sept. 23, 2019, the Federal Deposit Insurance Corporation’s (FDIC) Office of the Ombudsman published its 2018 Annual Report. The Ombudsman Office serves as part of an alternative dispute resolution process and this is the first public report it has issued in almost ten years. The Ombudsman Office handled a total of 142 cases and conducted outreach visits to 472 banks, trade associations and state banking authorities. The top topic of interest was regulatory issues. Of the regulatory issues, 26% involved the regulatory burden, 16% Truth in Lending and Real Estate Settlement Procedures Act Integration (TRID), 15% Bank Secrecy Act (BSA), 7% Home Mortgage Disclosure Act (HMDA) and 5% marijuana. A regulatory burden concern was HMDA reporting requirements make it challenging for banks to increase their mortgage lending activities. TRID concerns included that disclosure requirements are costly, impact mortgage profitability, and confuse consumers. BSA concerns included burdensome beneficial ownership rules and an outdated $10,000 Currency Transaction Report threshold. Marijuana concerns sought greater transparency in exam procedures regarding marijuana-related businesses.


John Zasada, JD, CAMS – Compliance Consulting Director, Financial Institutions Group. John can be reached at zasada@doeren.com.