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June 9, 2010
Phil Angelides
Via Email and First Class Mail
Mr. John C. Dugan
Comptroller of the Currency
250 E Street SW
Washington, DC 20219
Ann. taylor(aJ,occ. treas. gov
Cllili rlllall
Re:
Hon. Bill Thomas
Follow-Up to the Financial Crisis Inquiry Commission Hearing
on AprilS, 2010
Vice '!airmall
Dear Comptroller Dugan:
Brooksley Born
Comm issioller
Byron S. Georgiou
COlli III issioller
Senator Bob Graham
On April IS, 2010, Chairman Angelides and Vice Chairman Thomas sent you a
letter thanking you for testifying at the April 8, 2010 hearing and informing you
that the staff of the Financial Crisis Inquiry Commission ("FCIC") would be
contacting you or your office to follow-up on certain areas of your testimony and
to submit written questions and requests for information related to your testimony,
which are listed below. Please provide your answers and any additional
information by June 23, 20 I O. I
COlt/Ill issioller
1.
What were the annual default rates for subprime and Alt-A loans, in
absolute terms and relative terms, for national banks as compared to the
industry average from January I, 2004 to December 31, 2009?
2.
Please provide detailed information (who, when, and how) and a timeline
regarding the following:
Keith Hennessey
Commissioller
Douglas Holtz-Eakin
COllllllissioner
Heather H . Murren, CFA
Colt/lIlissioner
John W. Thompson
(a) Any and all instances in which the oce 2 requested from state law
enforcement officials and consumer groups information or referrals
related to incidents of deceptive conduct, unfair lending, predatory
Commlssioller
Peter J. Wallison
COlllmissioner
I The answers you provide to the questions in this letter are a continuation of your testimony and
under the same oath you took before testifying on April 8,20 I O. Further, please be advised that
according to section 1001 of Title 18 of the United States Code, "Whoever, in any matter within
the jurisdiction of any department or agency of the United States knowingly and willfull y falsifies,
conceals or covers up by any trick, scheme, or device a material fact or makes any false, fictitious
or fraudulent statements or representations, or makes or uses any false writing or document
knowing the same to contain any false, fictitious or fraudulent statement or entry, shall be fined
under this title or imprisoned not more than five years, or both ."
2 "OCC" refers to the Office of the Comptroller of the Currency and any of its members, divisions,
and offices, including its national, regional or local offices and all other persons acting or
purporting to act on its behalf.
1717 Pennsylvania Avenue, NW, Suite 800 • Washington, DC 20006-4614
Wendy Edelberg
Executive Director
202.292.2799 • 202.632.1604 Fax
.-0-
*
Comptroller Dugan
June 9, 2010
Page 2 of2
lending, mortgage fraud, boiler room-type conduct, or aggressive
lending on the part of national banks;
(b) Any related responses received from any such authorities or consumer
groups; and
(c) Any further actions taken by the
information or referrals.
acc in response to any such related
The FCIC appreciates your cooperation in providing the information requested. Please
do not hesitate to contact Jeff Smith at (202) 292-1398 or jsmith@fcic.gov if you have
any questions or concerns.
Sincerely,
Wendy Edelberg
Executive Director
Financial Crisis Inquiry Commission
cc:
Phil Angelides, Chairman, Financial Crisis Inquiry Commission
Bill Thomas, Vice Chairman, Financial Crisis Inquiry Commission
Jeff Smith, Investigative Counsel, Financial Crisis Inquiry Commission
4843-5647-5398 . v. I
C)
Comptroller of the Currency
Administrator of National Banks
Washington, DC 20219
HAND DELIVERED
July 8, 2010
Financial Crisis Inquiry Commission
1717 Pennsylvania Avenue, NW, Suite 800
Washington, DC 20006-4616
Attention: Jeff Smith, Investigative Counsel
Subject:
OCC Response to June 9. 2010. Follow-Up Request for Information Related to
Comptroller Dugan's testimony on April 8. 201 0
Dear Mr. Smith:
Pursuant to the June 9, 2010, follow-up request of the Financial Crisis Inquiry Commission
("FCIC") to Comptroller John C. Dugan related to his testimony before the FCIC on April 8,
2010 ("Request"), the OCC hereby responds as follows:
Item One
On June 21,2010, you verbally agreed to accept Appendix B and the chart on page 9 of the
Appendix attached to the Comptroller's April 8, 2010, testimony in response to question #1
regarding annual default rates for subprime and Alt-A loans for national banks, as compared to
the industry average, from January 1, 2004 to December 31, 2009. The verbal agreement was
confirmed via email on June 21,2010. On July 6,2010, you emailed the OCC seeking
additional information regarding question #1. The OCC is working to respond to this request.
Item Two
Please see the enclosed timeline and attached supporting documentation, bates numbered
OCC14-00300838 - OCCI4-00300852, describing OCC communication with state law
enforcement officials and consumer groups regarding information sharing, complaint referrals
and responsive OCC action related to deceptive conduct, unfair or predatory lending, mortgage
fraud, boiler room-type conduct, or aggressive lending on the part of national banks. The
timeline covers a period of approximately 2003 through Spring 2010. The enclosed timeline and
supporting documents provide the information requested in your July 6,2010, email regarding
then-Comptroller of the Currency, John D. Hawke's meeting with certain State Attorneys
General.
Pursuant to an Agreement Regarding Confidentiality of Non-Public Information signed January
8,201 0, and January 11, 2010, by the FCIC and OCC, respectively ("Agreement"), the OCC
I
••
Jeff Smith
Investigative Counsel
July 8,2010
Page 2
hereby designates the produced material as "non-public OCC information" protected by the
terms of the Agreement. All of the documents provided to you contain confidential, non-public
OCC information subject to the Agreement. In addition, and pursuant to 12 U.S.C. § 1821(t),
disclosure of the enclosed documents and information to the FCIC does not waive any associated
privileges.
Should you have any questions, please call Linda Bridgman, Erica On sager, or Alissa Sagri at
(202) 874-4800.
Sincerely,
Richard C. Steams
Director
Enforcement and Compliance
Enclosures (2)
cc:
Daniel P. Stipano
OCC Deputy Chief Counsel
Linda Bridgman
Assistant Director of Enforcement and Compliance
Michael Gordon
Counselor to the General Counsel
U.S. Department of the Treasury
-2-
OCC Timeline in Response to June 9, 2010 Request, Number 2
Page 1 of9
BACKGROUND
Communication with Consumer Organizations: The Comptroller, First Senior Deputy
Comptroller/Chief Counsel, and Deputy Comptroller for Community Affairs periodically
meet with the following consumer organizations to keep abreast of consumer protection
concerns with national banks:
California Reinvestment Coalition
Center for Responsible Lending
Chicago CRA Coalition
Consumer Action
Consumer Federation of America
Consumer's Union
CRA Coalition of North Carolina
Greenlining Institute
National Association of Consumer Advocates
National Community Reinvestment Coalition
National Consumer Law Center
National Consumers League
National People's Action
Neighborhood Economic Development Advocacy Project (NEDAP)
US Public Interest Research Group
Woodstock Institute
The following timeline refers to communications with the foregoing consumer groups
that resulted from the periodic meetings.
Complaint Processing Function: The OCC's Customer Assistance Group ("CAG"),
with the assistance of other relevant OCC units, processes complaints and inquiries from
customers of national banks. In 2009, CAG received over 90,000 inquiries and over
72,000 complaints. Reimbursements to customers achieved through the complaint
process totaled $9,240,043 in 2009.
The OCC routinely communicates with state officials as part of its complaint processing
function. As described below, from 2006 to the present, forty-four states and Puerto Rico
have entered into Memoranda of Understanding ("MOUs") with the OCC to facilitate
information sharing regarding consumer complaints. For thirty-six states, complaints are
transferred electronically to the OCC from state agencies. CAG periodically provides
information to the referring state agencies regarding disposition of complaints. On
occasion, attorneys in the OCC's Law Department communicate with state officials
directly regarding issues that arise regarding individual complaints that have been filed
with CAG.
acc Timeline in Response to June 9,2010 Request, Number 2
Page 2 of9
During April 1998 to May 31, 2010, the acc received over 63,000 complaints forwarded
from state officials. When the acc receives a complaint, CAG analysts record
information in CAG's database about the type of financial product and claim that are at
issue. During 2000 to May 31,2010, state officials referred 470 complaints that CAG
coded as involving claims of predatory lending or unfair or deceptive acts or practices.
Cases involving allegations of predatory lending or unfair or deceptive practices
generally are reviewed by CAG personnel in close consultation with the Law
Department.
Licensing Function: The acc is charged under various federal statutes with
considering applications involving the chartering, structure, activities, and operations of
national banks. Some types of applications require that the applicant give public notice
of the application, inform the public that comments may be submitted to the acc
concerning the application, and provide the closing date of the public comment period.
For a variety of applications, the acc considers the convenience and needs of the
community served. Additionally, for many types of applications the acc considers the
applicants' record of performance under the Community Reinvestment Act. See 12
C.F.R. Part 5; 12 U.S.C. §§ 2903(a)(2), 2902«3); 12 C.F.R. § 25.29.
In the course of processing corporate applications, the acc routinely receives
communications from members of the public, including community groups, expressing
concerns about proposed transactions. Additionally, the Federal Reserve Board routinely
forwards letters from members of the public on holding company applications that are
related to applications pending before the acc. an a number of occasions, the concerns
expressed in these letters have involved allegations of predatory, unfair, or deceptive
conduct by the applicants or their affiliates. These letters are carefully evaluated in
determining the appropriate action on pending applications and are addressed in acc
decisions.
TIMELINE
The following timeline summarizes communications with state officials and community
groups involving allegations of deceptive conduct, unfair lending, predatory lending, or
mortgage fraud on the part of national banks, from January 1,2003, to the present.
~
an March 5, 2003, then-Comptroller of the Currency, John D. Hawke, Jr., sent a
letter to Tom Miller, Attorney General of Iowa, following an in-person meeting
the previous week in Washington, D.C of the acc and States Attorneys General
for Iowa, North Carolina, Pennsylvania, Vermont, and Washington. The letter
reiterated Hawke's position at the meeting that the acc and state authorities
should explore how to partner to enhance effective and efficient protections for
customers of national banks. Copies of the letter were sent to the other Attorneys
OCC Timeline in Response to June 9, 2010 Request, Number 2
Page 3 of9
General who attended the meeting. See OCCII-00211138 and OCCll00211141.
~
In March 2003, the OCC district counsel staff held discussions with Arizona
Attorney General's Office ("AG's Office") staff regarding whether the AG's
Office would coordinate with the OCC in settling a matter with Household Bank
(SB), N.A., regarding the bank's financing of door-to-door sales of heating,
ventilation, and air conditioning systems. The AG's Office declined to join in the
OCC's Formal Agreement, which was entered on March 25,2003. Formal
Agreement By and Between Household Bank (SB), N.A., and OCC, No. 200317. See http://www.occ.treas.govIFTP/EAs/ea2003-17.pdf.
~
In June 2003, ACORN contacted the OCC to express concerns that Wells Fargo
was allegedly engaged in predatory lending. ACORN transmitted factual
information about a number of individual consumers who allegedly had been
harmed by the subprime lending operations of WFHM, a national bank
subsidiary, and Wells Fargo Financial, a non-bank holding company subsidiary.
In August 2003, the OCC's First Senior Deputy Comptroller and Chief Counsel
met with ACORN staff members to discuss the complaints and ACORN's
concerns. A follow up teleconference was held with ACORN staff members and
OCC Law Department, Community Affairs, and CAG staff.
In response to ACORN's concerns, the OCC facilitated the filing of complaints
regarding individual consumers with CAG. Information regarding the complaints
was transmitted to the OCC's Large Bank Supervision staff for review and
follow-up. The OCC included Wells Fargo's commitments regarding policies and
procedures to address customer referral practices, subprime lending operations,
and relationships with mortgage brokers as conditions in a November 6, 2003
decision to approve a corporate application. See
http://www.occ.treas.gov/interp/dec03/cradI18.pdf.
~
. In June 2003, the OCC met with National People's Action to discuss concerns
regarding predatory mortgage lending matters. On February 2,2005, the OCC
issued mortgage lending guidelines addressing many concerns about mortgage
practices. See
http://l1'WW.occ. treas.gov/tooikit/newsreiease.aspx?Doc=ERNFCQX9.xml.
~
On July 25,2003, then-Comptroller of the Currency, John D. Hawke, Jr., sent a
letter to Tom Miller, Attorney General of Iowa, reiterating the invitation of his
March 5th letter to Attorney General Miller for the OCC and state authorities to
partner to address consumer protection issues. Attached was a proposed MOV for
the purpose of sharing consumer complaints and other information regarding
alleged violations oflaws applicable to national banks and their subsidiaries. The
letter was cc'd to Sarah Reznek at the National Association of Attorneys General
(''NAAG'') and State Attorneys General. See OCCII-00211141.
OCC Timeline in Response to June 9, 2010 Request, Number 2
Page 4 of9
~
On August 13,2003, then-Comptroller of the Currency, John D. Hawke, Jr., sent
a letter identical in all substantive respects to his July 25, 2003, letter to Neil
Milner, President and CEO of the Conference of State Bank Supervisors, with the
expectation that it would be provided to state bank supervisors. Comptroller
Hawke expressly requested that if state bank supervisors become aware of any
illegal, predatory, unfair, or deceptive practices at national banks that they bring
those practices to the OCC's attention so appropriate action could be taken. See
Attached OCC14-00300838.
~
On October 7,2003, Attorney General Miller sent a response letter to thenComptroller Hawke rejecting the proposed MOU as being "one-sided". See
OCC11-00284324.
~
On October 16,2003, then-Comptroller of the Currency, John D. Hawke, Jr., sent
another letter in response to Attorney General Miller's October 7, 2003, letter.
Comptroller Hawke extended to Miller and his States Attorney General
colleagues a second invitation to enter into discussions on drafting a MOU
satisfactory to all parties. See AttachedOCC14-00300842.
~
On October 29,2003, then-Comptroller of the Currency, John D. Hawke, Jr., sent
a letter to Roy Cooper, Attorney General of North Carolina. Comptroller Hawke
reiterated his request in his July 25, 2003, letter to bring all complaints about
national banks to the OCC's attention; and stated that the OCC was open to
discussions about drafting a MOU satisfactory to all parties. See OCC1100196004.
~
In December 2003, the OCC notified the Illinois and Missouri States Attorneys
General of the findings of an investigation the OCC had conducted concerning
certain student loans provided by a national bank to students and prospective
students of a vocational school. The investigation had been prompted by letters
that the OCC received in November 2002 from those Attorneys General offices.
The OCC opened an investigation into the matter; carefully reviewed all of the
information; and ultimately determined that the bank had not engaged in any
unfair or deceptive practices in violation of federal or state law in connection
with these loans. Notwithstanding this, the OCC did raise supervisory concerns
about the bank's oversight of the program and, in response to those concerns, the
bank agreed to take several steps to avoid, minimize, and mitigate the risks to the
bank and its customers relating to its vocational school student lending activities.
~
On various occasions during early to mid-2004, the OCC had communications
with community groups about concerns with bank credit card disclosures of
practices such as universal default. The OCC issued an industry advisory letter on
credit card practices and undertook a comprehensive review of disclosures
OCC Timeline in Response to June 9,2010 Request, Number 2
Page 5 of9
provided by large national bank credit card issuers, which resulted in revised and
improved disclosures. See http://wv..W.occ.treas.gov/f.tp/advisory/2004-1 O. txt
~
In February 2004, the OCC received a communication from Consumer's Union
following up on a previous meeting to discuss payroll cards. Consumer's Union
identified questions and concerns regarding the product. In May 2004, the OCC
issued Advisory Letter 2004-6 on regulatory expectations concerning operation
of payroll card programs which addressed many of these issues. See
http://v,rww.Dcc.treas.gov/ftp/advis01y/2004-6. txt
~
On February 26,2004, the OCC issued an industry advisory letter providing
guidance to national banks regarding how to respond to complaints from state
officials and on appropriate complaint resolution processes. Additionally, in the
advisory letter, the OCC encouraged state officials to bring to its attention any
complaints that allege that national banks are engaging in any illegal, predatory,
unfair or deceptive practices. The OCC requested that state officials forward
individual customer complaints involving such allegations to CAG, while
national bank practices affecting multiple customers be brought to the attention
ofthe OCC's Office of Chief Counsel. See
htlp:llwww.occ.treas.gov/Advlst04.htm.
~
On February 27,2004, then-Ombudsman Samuel P. Golden sent letters to
Randall S. James, the Texas Commissioner of Banking, and Roy Cooper, North
Carolina Attorney General, inviting discussion of ways to improve the process
for responding to consumer complaints among state and federal agencies. See
Attached OCC14-00300843-00300846.
~
On March 26, 2004, Senior Deputy Attorney General of North Carolina, Josh
Stein, replied to the OCC's February 27,2004, letter on behalf of Attorney
General Cooper noting the Attorney General's objection to the OCC's position
on preemption but agreeing to discuss how best to communicate to consumers
how various government agencies can assist them. See Attached OCC 1400300847.
~
On April 2, 2004, then-Ombudsman Samuel P. Golden and North Carolina
Senior Deputy Attorney General Josh Stein, had a telephone conversation
discussing how to best share CAG complaints.
~
On April 9, 2004, then-Ombudsman Samuel P. Golden sent a letter to North
Carolina Senior Deputy Attorney General Josh Stein, thanking him for the April
2,2004, telephone discussion, and inviting a dialogue (1) to improve the process
of referrals of consumer complaints among state and federal agencies, (2) to
clarify and improve consumers' awareness of where and how to file complaints
against banks, (3) to identify steps the states may take if they become aware of an
unsafe or unsound, unfair, or deceptive practice by a national bank or its
OCC Timeline in Response to June 9, 2010 Request, Number 2
Page 6 of9
subsidiaries, and (4) to enhance communication between the OCC and the states
on consumer protection more broadly. OCC14-00300849.
~
During winter and spring of 2004, the MOUs were revised to address concerns
voiced by state AGs.
~
During the late summer of 2004, copies of the revised MOUs were provided to
the Conference of State Bank Supervisors, the New York State Banking
Superintendent, and the North Carolina Commissioner of Banks.
~
On October 27,2004, then-Ombudsman Samuel P. Golden sent a letter to Roy
Cooper, North Carolina Attorney General, following the OCC's letters and
subsequent telephone discussions with North Carolina Senior Deputy Attorney
General Josh Stein. The letter requested an in-person meeting to an open
dialogue regarding, inter alia, consumer complaint referrals. See Attached
OCC 14-00300848.
~
On November 18, 2004, the OCC provided a copy of a revised MOU to the
Consumer Protection Division of the North Carolina Department of Justice. At
that time, the North Carolina Attorney General was the Chair of the National
Association of Attorneys General Consumer Protection Committee. No response
was ever received. See Attached OCC14-00300851.
~
In 2006, the OCC met with a number of consumer groups to discuss an
interagency Non-Traditional Mortgage Lending Guidance under consideration by
federal banking agencies. See
http://www.occ.treas.gov/fr/fedregisterI70fr77249.pdf. Those groups had
recommended that the non-traditional mortgage lending guidance be expanded to
include 2/28 and 3/27 adjustable rate mortgages. Guidance including the
requested products was issued in June 2007. See
http://www .occ. treas. gov/fr/fedregister172fr3 7569. pdf
~
In July 2006, Comptroller Dugan met with a number of community groups to
discuss continuing concerns with credit card lending practices and disclosures.
The OCC continued to review credit card solicitations and disclosures for
compliance with applicable laws, regulations, and guidance. Additionally, OCC
officials voiced their support on a number of occasions for the Federal Reserve
Board's rulemaking to review and revise the Regulation Z provisions relating to
credit cards. See, e.g., Testimony of John C. Dugan before the Subcommittee on
Financial Institutions and Consumer Credit, H.R. Committee on Financial
Services (June 7, 2007), http://www.occ.treas.gov/fip/releaseI2007-54b.pdf
~
In July 2006, the OCC received correspondence from US Public Interest
Research Group following up on a meeting with Comptroller Dugan. The US
Public Interest Research Group identified a problem one of their constituents was
OCC Timeline in Response to June 9, 2010 Request, Number 2
Page 7 of9
having with a Citibank credit card. CAG was able to resolve the matter to the
satisfaction ofthe customer.
~
On November 20, 2006, the OCC announced an agreement on procedures for the
exchange of consumer complaint information between state banking departments
and the OCC. See
http://www.occ.treas.gov/toolkitinewsrelease.aspx?JNR=l&Doc=D39TFJ65.xml
~
Starting on November 30, 2006, the OCC entered into MOUs with the following
states:
New York
11130/06
12/04/06
North Dakota
12115106
Arizona
Mississippi
12/31/06
Georgia
02/02/07
Missouri
02/08/07
Wyoming
02/08/07
North
Carolina
02/20107
Colorado
02/28/07
03/02/07
Kentucky
03129107
Louisiana
New
Hampshire
04/09/07
Nebraska
04/17/07
04126107
Florida
South Dakota
05/01/07
05110107
Utah
05114/07
Maine
Wisconsin
05/18/07
Pennsylvania
05/30107
Puerto Rico
06/29/07
07118107
Alaska
Vermont
07/20107
07/23/07
Ohio
07/30107
Illinois
08/06/07
Indiana
08120107
Washington
Montana
08/28/07
10102/07
Texas
10105/07
Delaware
10/31/07
Alabama
10/31/07
California
Arkansas
11127/07
12118/07
Rhode Island
·'
OCC Timeline in Response to June 9, 2010 Request, Number 2
Page 8 of9
Iowa
Massachusetts
Minnesota
Connecticut
Idaho
New Jersey
West Virginia
Oregon
Oklahoma
Michigan
Tennessee
Kansas
~
12/21/07
01118108
02114/08
03/31/08
04128108
06/01/08
06/04/08
06/05/08
07/01/08
08/01/08
08/01/08
10107/08
On April 17, 2007, the Deputy Attorney General of California, Howard Wayne,
made a referral to CAG on behalf of two former students of MicroSkills, a failed
computer training school, who had borrowed student loans from a national bank.
The OCC contacted Wayne by phone on May 3,2007, to inform him that the
OCC was looking into the matter and to seek any additional information his
office had in connection with the bank and MicroSkills. In response, Wayne
submitted materials identifying twelve additional students who claimed to have
borrowed from the bank to finance their attendance at MicroSkills. Wayne
complained that the bank was refusing to honor the holder in due course
provision in the loan contracts.
After the OCC contacted the bank, it reversed its earlier position and agreed to
honor the holder in due course clause in all of the disputed contracts, if contacted
by the studentlborrowers. The OCC disagreed with the bank's approach and on
June 15,2007, the OCC informed the bank of its expectation that it should reach
out to all potentially affected MicroSkills students to alert them that they might
have a claim and to solicit facts to determine the amount, if any, of such claim.
The bank did so by letters dated June 21,2007, to all affected borrowers. The
OCC periodically monitored the bank's follow-up on the affected borrowers and
ultimately the bank satisfactorily addressed all the issues raised by the complaint.
~
Following Capital One's conversion to a national bank charter on March 1,2008,
the OCC reached out to State Attorneys General in California and West Virginia
concerning matters that were under investigation by those offices. The OCC
made various requests during the summer of 2008 to the offices of the California
and West Virginia Attorneys General for information pertaining to consumer
complaints against Capital One. The California Attorney General produced
approximately three boxes of documents, including consumer complaints filed
with Capital One, meritorious consumer complaints filed with the California
Attorney General's Office, and documents produced by Capital One in response
to the California Attorney General's requests. The West Virginia Attorney
•
I
OCC Timeline in Response to June 9,2010 Request, Number 2
Page 9 of9
General's Office produced 356 consumer complaints filed with their office,
almost all of which the OCC determined, following careful review, were not
actionable. In addition, based upon the information obtained from the California
and West Virginia Attorney Generals, the OCC performed a targeted review of
credit card practices focused on their areas of concern. After finalizing
examination conclusions, the OCC imposed a Formal Agreement against Capital
One on February 18,2010, requiring the bank to pay $750,000 to affected
customers. The OCC continues to investigate certain additional allegations made
by the West Virginia Attorney General's Office in a January 1, 2010, complaint
filed against the bank in the Circuit Court of Mason County, West Virginia.
~
In September 2009, the OCC received a communication from Consumer
Federation of America concerning allegedly abusive overdraft protection
program practices at Old National Bank. The OCC reviewed Old National
Bank's practices and the bank to adjust its practices to conform to the 2005
Interagency Guidance on Overdraft Protection programs.
~
In 2009 and early 2010, consumer groups communicated concerns with national
banks' refund anticipation loan programs. The OCC issued Bulletin 2010-7 on
February 18,2010, addressing supervisory expectations regarding the operation
of Refund Anticipation Programs offered by national banks. See
http://www.occ.treas.govlftplbulletin/2010-7a.pdf. In February 2010, the OCC
also issued a consumer advisory on ways consumers can receive their tax
refunds, along with a public service announcement. See
http://rvww.occ.treas.gov/ftpIADVISORYI2010-1.html.
~
In December 2009, the OCC Law Department staff held a telephone discussion
with staff attorneys at the California Department of Justice to obtain information
on civil litigation brought by the state against a tax preparer that offered refund
anticipation loans extended by a national bank. The California attorneys
provided the OCC staff background information on the litigation. In January
2010, the state attorneys also forwarded state court pleadings. The national bank
in question is no longer involved in refund anticipation loan lending.
~
In the spring of 201 0, OCC received communications from consumer groups
identifying concerns with the way a national bank was planning to operate its
overdraft program under the new Federal Reserve Board overdraft protection
regulations. Some of these issues had been the subject of earlier press accounts.
In April 2010, OCC issued Bulletin 2010-15 addressing the concern by clarifying
regulatory expectations as to how banks should be implementing the Federal
Reserve Board's regulatory changes on overdraft protection programs. See
http://occ.gov/ftplbulletinl2010-15.html.
_. ,.,- .- ---.or- - : - - ..-.... --- ...... __ .
,
,
"
."
Comptroller of the Currency
Administrator of National Banks
Washington, DC 20219
August 13, 2903
~. ~eil~ilner
President & CEO
Confer~nce of State Bank Supervisors
1155 Connecticut Avenue, ~:W.
Washington, D.C. 20036
Subject:
."
Handling of Consumer Complaints,
Dear~eiI:
I am writing to n;take you and your CSBS colleagues aware of new arrangements that the acc
has put in place to improve communication 'and coordination in connection with referrals 'of
customer complaints regarding national banks or their subsidiaries made by State agencies to the
acc. I know we all share the goal of providing effective and efficient protection for customers
of national banks, and I firmly believe that the States and the aCC can partner in this effort,
entirely within the parameters set out in federal law fo'r supervision and regulation of national
banks by the acc. I wanted to make,you aware of the specifics are what we are doing in this
regard. We also have been in touch with the State Attorneys General to convey similar
information about our new arrangements. '
By way of brief background, as you know, our supervisory processes are tailored to each bank's
size -large, mid-~ize, and community - and to the bank's particular business operations, when
these operations affect the risk profile of the bank (such as credit card banks). In our largest
, national banks, this process entails continuous supervision by a staff of OCC examiners onsite at
the bank. Examinations for compliance with consumer protection laws is an important
component of our supervisory responsibilities, 'and, as with safety and soundness examinations,
we try to tailor our consumer compliance exams and other supervisory activities to the risk
profile of a particular bank or type of banks. Customer complaint information, including
information that we may receive from State agencies 'or departments, can play an important role
in that regard.
The acc's Customer Assistance Group (CAG), based in Houston, Texas, has an important role
in processing and resolving individual customer complaints and analyzing and channeling
complaint infonnation to our bank examiners to enable exaininers to intensify their supervisory
Confidential & Non-public
acc Information
aCC14-00300838
.
.
activities for particular problematic institutions. The CAG is comprised of teams of consumer
complaint specialists, analysts, and bank examiners, and is overse~n by the OCC's Ombudsman.
.In addition to handling a large volume of questions and general comments about national banks
or banking laws and regulations, CAG teams process thousands of individual customer
complaints each year. Complaints range from alleged violations oflaw or regulation to
contractual disputes and customer service issues. The CAG receives these complaints via
telephones to its toll-free number, electronic mail through 24-hour access to the CAG website, as
well as written correspondence.!
With respect to all' of the written and Email complaints, and roughly half of the telephone
· complaints that cannot be resolved dUring the course of the initial call, the complaint will be sent
to a special processing unit for research and bank contact. ~ certain instances, the CAG
specialist will consult, as appropriate, with acc legal staff for guidance. The CAG will respond
to the consumer after it concludes its research into the ~atter and has evaluated the information it
has obtained from the consumer and the b~ (or subsidiary) that is the subject of the complaint.
· This complaint resolution and informal mediation process enables the CAG not only to assist
consumers, but also to develop a large and flexible base of consumer complaint information that
can be analyzed by bank, by product, and by subject matter of the complaint. The CAG uses this
database to prepare internal reports for bank supervision staff on complaint volumes and trends.
Bank examiners also may access the CAG database directly to assist them in identifying risk
management issues, potential violations oflaw ands appropriate supervisory strategies for
· individual banks. We take pride in the fact that the CAG has been - deservedly -- recognized as
supervision of the national banking system.
a unique and valuable component of the
qcc's
I lmow you and I agree that Federal and State hank supervisors share a common goal of ensuring
that consumers are protected from illegal, predatory, unfair, or deceptive practices. 2 In our
For your information, the contact information is as follows:
1) Letter - Comptroller of the Currency, Customer Assistance Group, 1301 Mc~ey Street, Suite 3450,
Houston, Texas 77010;
2) 2) Telephone - 1-800-613-6743; and
3) . 3) Email- customer.assistan!=e@occ.treas.gov. .
.
2 I have made clear on a number of occasions that predatory and abusive practices have absolutely no place in the
national banking system. I also ~ust note that in my meetings with consumers who have been the victims of
predatory lending practices, I have been told, consistently, that the lender at issue was a finance company or a loan
.broker, not an insured bank or its subsidiary. Notably, nearly two dozen State Attorneys General filed a brief in
litigation earlier this year that reaches the same conclusion. The case, National Home Equity Mortgage Association
· v. Office o/Thrift Supervision, No. 1:02CV02506 (D.D.C. 2003), involves a revised regulation issued by the Office
of Thrift Supervision (OTS) to implement the Alternative Mortgage Transaction Parity Act (AMPTA). The revised
regulation seeks to distinguish between federally-supervised thrift institutions and non-bank mortgage lenders and
makes non-bank mortgage lenders subject to state laws restrictions on prepayment penalties and late fees: In
supporting the OTS's decision to distinguish between Supervised depository institutions and unsupervised housing
creditors and to retain preemption ofstate laws with respect to.the former, but not for the latter, the brief for the
State Attomeys General stated:
I
Based on consumer complaints received, as well as investigations and enforcement actions undertaken by
the Attorneys General, predatory lending abuses are largely confined to the subprime mortgage lending
-2-
Confidential & Non-public OCC Information
OCC14-00300839
-. 1
supervision of the nationali>anking system, we have an extensive array oftools with which to
address unsafe or unsound or unfair and deceptive practices or violations of law by national
banks. We have the ability to issue administrative cease and desist orders, safety and soundness
directives, require restitution, remove officers and directors and impose civil money penalties.
TIlrough our supervisory processes, we also have immediate access to bank information and
bank personnel, without the need for issuance of subpoenas. All these tools enable us to respond
with speed and focus and achieve appropriate compliance and remedial measures from the
national banks we supervise.
While the CSBS has raised some question about the scope of our exclusive visitorial powers with
respect to national banks and their subsidi;¢es, I believe our authority in this regard i~ quite
clearcut, as provided under Federal law, 12 U.S.C. § 484. Moreover, I think it is quite clear that
our authority extends not only to safety and so~dness matters, but to consumer protection and
other matters as well. Putting our difference on this legal issue aside, however, I think there a
way to proceed, that we will agree is constructive, as·follows.:
,..
If State bank supervisors become aware of complaints that allege that national banks or their
subsidiaries are engaged in any illegal, predatory, unfair or deceptive practices, I strongly urge
State supervisors to bring those to our attention so that we may take appropriate action. To the
extent that the matter involves an individual customer grievance, the complaint would
appropri"ately be sent to the CAG. Where the issue is broader, such as the applicability of a
particular State law to national banks generally, or ifthere is infonnatioD, that a specific national
bank is engaged in a particular practice affecting multiple customers that is predatory, unfair or
deceptive, this information should be communicated to the OCC's Office of Chief Counsel for
coordination.
.
.
We have established special procedures to handle both types of referrals. With respect to
referrals to the CAG, infonnation should be directed as follows and will be flagged and specia.J.iy.
tracked:
Comptroller of the Currency
.Customer Assistance Group
Attention: Craig D. Stone, Deputy Ombudsman/State Referral
1301 McKinney Street, Suite 3450
Houston, Texas 77010
Mr. Stone may also be ~eached at 713-336-4350 and at Craig.Storie@occ.treas.gov.
market and to non-depository institutions. Almost all a/the leading subplime lenders are mortgage
companies andfinance companies, not banks or direct bank subsidiaries. (emphasis added)
-3.-
Confidential & Non-public
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aCC14-00300840
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Information and issues of the type- appropriate for referral to the OCC's Law Department should
be directed as follows, and will also be specially tracked:
Comptroller of the Currency
.
. Chief Counsel's Office
Attention: James F. E. Gillespie, Jr., Assistant ChiefCounsellState Referral .
250 E Street, S.W.
Washington, D.C. 20219
Mr. Gillespie may also be reached at 202-874-5200 and at James.Gillespie@occ.treas.gov.
\
.
We also recognize your interest in how these matters are resolved, and we have prepared, and I
enclose herewith: a draft of a model Memorandum of Understanding between the -aCC and a
State department or agency. Execution of such an agreement will greatly facilitate our ability to
provide information to apprise State officials of status and resolution of matters that have been
referred to the OCC.
We would welcome this opportunity to work together with you and your CSBS colleagues, to
.
promote fair treatm~t of customers.
Sincerely,
D. Hawke, Jr.
omptroller of the Currency
-4-
Confidential & Non-public
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aCC14-00300841
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Comptroller of the Currency .
Administrator of National Banks
Washington, DC 20219
October 16, 2003
Mr. Thomas J. Miller
Attorney General
State ofIowa
Department of Justice
Hoover Building
Des Moines, Iowa 50319
Dear Tom:
I'm sorry that you are unhappy with my remarks to the Women in Housing and Finance, but
when one of your number publicly denounces this office by charging that we are engaged in
"unrelenting efforts ... to undermine the states' ability to protect their citizens from fraudulent and
deceptive corporate practices" -- a highly.political and inflanunatory'charge 'that is~ in my view,
sheer nonsense - I believe it calls for a strong response. I recognize that you cannot control the
public utterances of all State Attorneys General, but I have,heard,.nothing in the way of a
repudiation oftllls. kind of extreme rhetoric from more moderate
and better. informed voices.
.
.
,
As to the.proper interpretation of our visitoricl powers,'I don't think: the issue is even close. .You
and your colleagues are asserting,an'authority that is categorically denied to you by federal law..
I'm afraid we will have to agree to disagree on this question, at least until it is settled by some
other authority.
'
" .,
,
"
,
Finally, it puzzles me that you are so' emphatic in r,ejecting an MOU that has 'neither been drafted
nor discussed. We extended an invitation to you and your colleagues many months ago to enter,
into discussions as,to how we might define a cooperative arrangement, and to date we have not
heard any constructive suggestions from you'. I don't know whether it will in fact be possible to
reach such an agreement, given your insistence on asserting a desire to be able to take.direct
~nforcement actions against national banks, but I continue to believe that a shared interest in
,protecting consumers should, at least, lead us to pursue some discussion ofthe matter. We
remain ready and willing to have such discussions.
.
"
Confidential & Non-public OCC Information
OCC14-00300842
c)
Comptroller of the Currency
Administrator of National Banks
,Office of the Ombudsman
1301 McKinney Street
Suite 3400
Hquston, TX 77010
, February 27, 2004
Mr. Randall S. James
Commissioner of Banking
, Th~ State of Texas
2601 North Lamar Blvd.
Aus~ TX 78705-4294
, , lid/!
,Dear~
As you may know, in my capacity as 'the Ombudsman for the Office of the Comptroller of
the Currency (OCC)~ I am responsible for supervision of the agency's Customer
'
Assistance Group. As also you may be aware, the Customer Assistance Group provides
direct assistance to cU$tomers of national banks and their subsidiaries, and also analyzes
complaint data and provides that analysis to oce examiners to assist them in their
examinations of national banks and,their subsidiaries. In the latter capacity, the Group's
activities supplement our examinatio~ compliance and enforcement staff. (We have
nearly 1700 examiners in the field; a significant number are compliance specialists, and
, over 300 of our examiners are resident, full-time at our largest'national banks, conducting
. qontinuous supervision. The examination staff also is supplementetl by dozens of
attorneys who handle enforcement and compliance matters.)
,
The purpose of this letter is twofold; first, my Deputy Ombudsman, Craig D. Stone, and I
are very interested 'in exploring whether there is a group of state banking commissioners
with which it would be appropriate to discuss' improving the process for referrals of
consumer complaints among state and federal agencies. Currently, many state agencies
refer to us complaints that they have received that pertain to national banks and their
subsidiaries. In tUm, the OCC gets literally thousands of cU$tomer complaints that pertain
to entities that we do not regulate, and we endeavor to refer those to the appropriate
federal or state supervisor of the entity. We would be interested in dis~ussing how this
process is working,
thoughts QD how to improve it. It may also be useful to discuss if
there is any uniform information that could be made available to consumers via agencies'
websites th.!tt would explain where to file complaints and what agency to contact with
and
Confidential & Non-public OCC Information
OCC14-00300843
.' j
.;
respect to particular entities. We would be happy to pursue these issues' in any forum that
would be appropriate.
:Additionally, we would like to eXtend an invitation to you andlor others that may be
.appropriate, to visit our offices in Houston, Texas. We welcome the opportunity to
provide you with a comprehensive overview of our operations, a presentation of our
.consumer complaint managemen~ system and associated supervisory tools, as well as a
tour of our facility. '
.
Lastly, I extend a personal invitation for you to visit our offices during your attendance at
the 2004 Texas Bankers Association (TBA) convention in late April. The Hilton
,
Americas Hotel and:the George Brown Convention Center, .the rnA convention site, are
lo~ted just a couple of blocks from our office.
"
r look forward to hearing from you soon.
(office) or.{281) 433-4181 (cell).
.
Please feel free to contact me at 713-336-4350
'
Sincerely,
S
Confidential & Non-public OCC Information
OCC 14-00300844
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Comptroller of the Currency
Administrator of National Banks
.
,I
'
Office of the Ombudsman
1301 McKinney Street
Suite 3400
Houston, TX n010
February 27, 2004
The Honorable Roy Cooper
Attorney General
North C/Il"Olina Department 9f Justice .
P.O,Box629
Raleigh, NC 27602·0629
Dear Attorney General Cooper:
'.
I am writing to you in your capacity as. Chair of the National Association of Attorneys
General Consumer protection Committee. I am the Ombudsman for the Office of the
Comptroller of the Currency (OCC) and have supervision of the agency's Customer
. Assistance Group. As you may be aware, the Customer Assistance Group provides direct
assistance to cuStomers of national banks and their subsidiaries, and also analyzes .
complaint data and provides that analysis to OCC examiners to assist them in their
examinations of national banks and their'subsidiaries. In the latter capacity, the Group··s
activ.ities $UPplement our examination, compliance and enforcement staff. (We·have
nearly 1700 examiners in the :qeld; a significant number are compliance specialists, and
over 300 of our examiners are resident, full·time at our largest national banks, col)ducting
continuous supervision. 'The examination staff also is supplemented by dozens of
attorneys. who handle enforcement and co~pliance matters.)
.. ~'. '
','
.:.
."
the purpo~e of this letter is twofold; first, my Deputy Ombudsman, Craig D. stone, and I
,are very interested in opening a dialogue with the Committee, (or whatever group would
be appropriate) to discuss improving the process for referrals of consumer complaints
among state and federal agencies. Currently, many state agencies refer to us complaints
that they have received that pertain to national banks and their subsidiaries. In tum, the
OCC gets literally thousands of customer complaints that pertain to entities that we do not
regulate, and we endeavor to refer those to the appropriate federal or state supervisor of
. the entity. We would be interested in discussing how this process is working, and
thoughts on how to improve it It may also be useful to discuss if there is any uniform
information.that could be made available to consumers via agencies' websites or
otherwise that would explain where to file co~pla.ints and what agency to contact with
Confidential & Non-public OCC Information
OCC14-00300845
respect to particular regulated entities. We would be happy to pursue these issues in any
forum that would be appropriate.
Additionally, we would like to extend an invitation to you andlor others that may be
appropriate, to visit our offices in Houston, Texas. We welcome the opportunity to
provide you with a comprehensive overview of our operations, a presentation of our
consumer complaint management system and as!!ociated supervisory tools, as well as a
tour of our facility.
'
.
If you need.any information Or have questions, please feel free to contact me at 713-3364350. I will give you a call in the near future to explore how we canjointIy pursue thes~
initiatives.
Confidential & Non-public OCC Information
OCC14-00300846
· ;:- ' t
:
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"Q'~I
State of North Carolina
ROY COOPER
Deparlmenl of Justice
ATTORNEY GENERAL
P. O. Box 629
RALEIGH
27602-0629
CONSL'r.tER PROTECTIOS
1919) 716-6000
Fax: '1919\ 716-6050
March 26, 2004
Samuel P. GoJden, Ombudsman
Office of the Ombudsman
. Office of the Gomptrqller of the Currency
. ·1301 McKinney Street
.
.Suite 3400
Houston, TX 77010
Dear Mr. Golden:
Attorney General Cooper forwarded your Jetter to me and asked that I, as his Consumer
.
Protection ch lef, reply on his behalf.
Protecting consumers is one 'of the Attorney General's top priorities. Accordingly, .he
agrees that consumers should experience as little confusion as possible when filing'complaints
with, or seeking assistance from, government agencies. He has asked me, therefore, to
discuss with you how the OCC refers complaints to state agencies and how state agencies can
effectively. refer complaints to the OCC. If consumers are contacting your Consumer
Assistance Group (CAG) with problems beyond your authority, it makes a great deal of sense
for·the CAG to know to which agency the problem should be referred. It may also be ai:::lvisable
to qiscuss ho.w be~t to communicate to consume~ r.~w various ..gov~r:n!l1~~t agencies can
assist them with their problems.
. ........
.. '
:. '.
As you know, Attorney General Cooper opposes the OCC's efforts to preempt state
consumer protection laws and to restrict state enforcement of those laws because he believes
those efforts will diminish the protections afforded to consumers. When It comes to clear1y
communicating to consumers about how their state and federal governments can serve them,
however, our agenCies can set our policy and legal disagreements aside. Please feel free to
call me at (919) 716-6006 to identifY. a mutually convenieFlt time to talk about these issues. At
that p.oint. I can gauge the availability and Interest of my colleagues In other states to Join us in
.
....
'.
this dis.c~ssion.
. We app~e~iate your interest in cooperating on this matter.
.,I
I
Sincerely,
/J~
Yos~ Stein
Senior peputy Attorney Gell~ral
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C)
Comptroller of the Currency
Administrator of National Banks
Office of the Ombudsman
1301 McKinney Street
Suite 3400
Houston, TX 77010
October 27, 2004
Mr. Roy Cooper
.Attorney Ganera1
North Carolina Department of Justice·
P. O. Box 629
Raleigh, NC 27602-0629
Dear Mr. Cooper:
I wanted to follow-up on our previous correspondence nnd telephone conversations with Senior Deputy
Attomey General Stein. Craig Stone and I will be in Charlotte on November 15th and 16th attending
scheduled meetings at one of the large nationol banp. We wanted to mend an invitation to yan and
yourstafi'to set-up a time to discuss theOCC's coJ1S1lIDClcomplaintprocess. Wehaveopantimeonfor
a breakfast meeting in the morning of November 15th. or could mange our schedule to have a meeting in
the early afternoon that same day. Should your schedule permit travel to Owlotte, we can mange a
meeting in one of our local offices.
Ai; previously discussed, we are very interested in opening a dialogue with your office to discuss several
topics, including methods to improve the process of refenals of consumer complaints among state and
federa1 agencies. We also want to focus on improvements to clarify and improve conSUDlClB' awareness
of where and how to file complaints against a national bank or a subsidiary of a national bank.
I look forward to hearing from you soon and if you need any information, please feel free to call me at
713-336-4350.
s/~
~~~en
Ombudsman
cc:
Josh Stein
Confidential & Non-public OCC Information
OCC 14-00300848
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C)
Comptroller of the Currency
Administrator of National Banks
Office of the Ombudsman
1301 McKinney Street
Suite 3400
Houston, TX 77010
April 9, 2004
Mr. Josh Stein
Senior Deputy Attorney General
North Carolina Department of Justice
P. O. Box 629
Raleigh, NC 27602-0629
Dear Mr. Stein:
It was a pleasure visiting with you via telephone last Friday, and I appreciate your March
26, 2004 letter on behalf of Attorney General Roy Cooper. As you are aware, I am the
Ombudsman for the Office of the Comptroller of the Currency (OCC), and have
responsibility for the agency's Customer Assistance Group. The Customer Assistance
Group provides direct assistance to customers of national banks and their subsidiaries,
and also analyzes complaint data and provides that analysis to OCC examiners to assist
them in their examinations of national banks and their subsidiaries.
°
Currently, many state agencies routinely refer consumer complaints that they receive against
National Banks and their subsidiaries to the OCC. Similarly, the OCC recoeives thousands of
customer complaints that pertain to entities that we do not regulate, and we endeavor to refer
those to the appropriate federal or state supervisor of the entity.
As I mentioned in my initial letter to Attorney General Cooper, Deputy Ombudsman, Craig D.
Stone, and I are very interested in opening a dialogue with your office to discuss several topics
including:
(1)
(2)
Methods to improve the process of referrals of consumer complaints
among state and federal agencies.
Improvements to clarify and improve consumers' awareness of where and
how to file complaints against banks.
Confidential & Non-public OCC Information
OCC 14-00300849
:--- -'
Alternatives that the states could take should they become aware of an
unsafe and unsound, unfair or deceptive, or any other banking practice by
a national bank or one of its subsidiaries that spawns concern.
Enhanced communication between the states and the OCC on consumer
protection related issues including regular interaction by the OCC with
state agencies (Attorney Generals and Banking Commissioners) through
attendance at regularly scheduled meetings.
(3)
(4)
Additionally, we would like to extend an invitation to you, and others that may be
appropriate, to visit our offices in Houston, Texas. We welcome the opportunity to
provide you with a comprehensive overview of our operations, a presentation of our
consumer complaint management system and associated supervisory tools, as well as a
tour of our facility.
I look forward to visiting with you during our call scheduled next Wednesday, April 14,
2004 at 10:30 a.m., EDT. Please do not hesitate to contact me whenever I can be of
assistance at 713-336-4350 or via email at Samue1.Golden@occ.treas.gov.
Sincerely,
Samuel P. Golden
Ombudsman
Confidential & Non-public
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aCC14-00300850
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I)
C)
Comptroller of the Currency
Administrator of National Banks
Office of the Ombudsman
1301 McKinney St. Suite 3400
Houston, TX 77010
November 18, 2004
Mr. Philip Lebman
Assistant Attorney General
Consumer Protection Division
North Carolina Department of Justice
P. a. Box 629
Raleigh, NC 27602-0629
.. 1// 1
~~
Thank you for taking the time to meet with us on Tuesd~y morning. I believe that we have
identified several areas .of common interest and I look forward to future meetings.
·As a follow-up to our meeting, we would welcome any reactions, comments, or suggestions you
might wish to provide on the revised model MOV on Infonnation Exchanges Regarding
Consumer Complaints. Ns we noted, the new version is intended to avoid any concession by one
party to jurisdictional views of the other party. Instead, the referring agency remains free to
make referrals based upon its views of the jurisdiction of the receiving agency. We hope that
this approach will be acceptable to you and other Attorneys General.
We would also welcome any suggestions you might have on how acc might improve its
consumer assistance process based on your experience in North Carolina. Please feel free to
contact Craig directly if you have any questions, comments or suggestions related to the
processing of consumer complaints.
Finally, we would welcome the opportunity for additional meetings with your office or a·broader
group of Attorneys General. We think there are a range of issues· that we might usefully explore
including:
1) Methods to improve the process o/referrals o/routine consumer complaints among state and
federal agencies. For example, acc would like to discuss the OCC's referral of complaints to
state agencies and, specifically, when we should refer complaints to Attorneys General as
opposed to the State Banking Depl!11Il1ents.
Confidential & Non-public OCC Information
OCC14-00300851
'.
2) Methods to improve co,nsumer awareness ofhow to file complaints against national banks.
For example, we would like to discuss the information available to consumers on government
web sites. As we noted during our discussion, the North Carolina web site is a: model in terms of
. providing on its web site specific information on how consumers with complaints against
national banks can contact the OCC CAG. Vnfortunately, not all states do this and we. would
like to explore whether we can establish model language and practices. Likewise, the oce site
does not presently provide contact information for state agencies even though some consumers
with complaints about state banks or entities come to the OCC site; we would like to discuss
what type of information we should post on our web site to help ~ose consumers.
3) Use o/technology to enhance efficiency in our cross referral of complaints. For example, we
would like to discuss whether we might be able to adopt systems that would allow our agencies
to USe secure e-mail to send each other referred complaints and supporting documents.
4) Establishment 0/ regular meetings between aee and State Attorneys General to address
issues ofcommon concern and general trends. For example, these periodic meetings might:
•
•
•
•
•
Share information about patterns of abuses, including emerging trends and ongoing
problems at financial institutions.
Discuss how participating agencies might better coordinate enforcement actions on
different types of institutions to ensure effective remedies.
Review how consumer complaints are handl~ inclurung how the process works
currently and suggestions on how to improve the process.
Collect and distribute information about best practices used by financial institutions to
avoid abusive,practices.
Support public education efforts to help consumers recognize and avoid abusive practices
in financial services. .
Again, I appreciate you meeting with us so early in the moming, and look forward to followingup on these areas of common interest. Please give my best regards to Roy and Josh and have a
.
wonderful Thanksgiving holiday and weekend.
xc:· Roy Cooper
Attorney General
Josh Stein
Deputy Attorney General
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Confidential & Non-public
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@FedFRASER