Federal Advocacy
NBA meets virtually and in DC for visits with Nevada's Senate and House delegates.
Next Visit: Fall 2022
State of Nevada
NBA works with state legislators during session years and with interim committees in off years. In additional to supporting efforts to promote financial literacy, affordable housing and economic development, we work to ensure Nevada is an environment where banks can provide the best products and services to customers.
Regulatory
Nevada Bankers engage with State and federal regulators regularly. Member feedback is a critical piece of helping regulators with their job of providing effective, safe and meaningful oversight.
Compliance Alliance
Compliance Alliance Question of the Week
- Q. The bank currently provides the risk-based pricing notice in accordance with model forms H-3 and H-4, under the FCRA and Regulation V, for loans secured and not secured by residential real estate, respectively. The bank does not employ a credit scoring model or a tiered system for pricing but is considering such an approach. Do these notices still satisfy the disclosure requirements in that case? Would those systems then require periodic testing under FCRA, or would that be more for purposes of fair lending?
- A. If you choose to adopt a risk-based price tier system, then providing model forms H-3 and H-4 will meet the risk-based pricing notice requirements as long as H-3 is used when the consumer requests an extension of credit that will be secured by 1-4 units of residential property and H4 for credit that will not be secured by 1-4 units of residential property. For testing purposes, under the FCRA, the system itself would not require periodic testing but examiners do test on the sufficiency of notices being sent out when you do use a tier-based system: VIII. Privacy — Fair Credit Reporting Act (fdic.gov), (pg. 6.29) - https://www.fdic.gov/resources/supervision-and-examinations/consumer-compliance-examination-manual/documents/8/viii-6-1.pdf Regulation V, § 1022.74 - https://www.consumerfinance.gov/rules-policy/regulations/1022/74/#d
Not a Compliance Alliance member? Learn more about membership with Compliance Alliance by attending one of our live demos:
Bank Exam prep center
They Asked Banks to Help. You Did. Now What?
Regulators and congress asked you to help your community and you did. Now, you’re wondering in what direction your exam will take you.
With the pandemic dramatically affecting the way your bank does business, exams will look different too. Your best preparation should include a look at what your peers have experienced in their recent exams. NBA members may Visit the Bank Exam Prep Center to learn more.