TAILIEUCHUNG - Office of the Comptroller of the Currency Board of Governors of the Federal Reserve System

Online business transactions generally involve ACH file origination and frequent interbank wire transfers. Since the frequency and dollar amounts of these transactions are generally higher than consumer transactions, they pose a comparatively increased level of risk to the institution and its customer. Financial institutions should implement layered security, as described herein, utilizing controls consistent with the increased level of risk for covered business transactions. Additionally, the Agencies recommend that institutions offer multifactor authentication to their business customers | Office of the Comptroller of the Currency Board of Governors of the Federal Reserve System JUNE 21 2012 Updated November 20 2012 FINANCIAL REMEDIATION FRAMEWoRk FREQUENTLY ASKED QUESTIONS Financial Remediation Framework Approach 1. What is the purpose of the Financial Remediation Framework The Office of the Comptroller of the Currency OCC and the Board of Governors of the Federal Reserve System FRB have developed the financial remediation framework the Framework to provide examples of situations where compensation or other remediation is required for financial injury due to servicer errors misrepresentations or other deficiencies. The independent consultants will use the Framework to recommend remediation for financial injury identified during the Independent Foreclosure Review. The servicers will prepare remediation plans based on the independent consultants recommendations. The federal banking regulators must approve each servicer s remediation plan. The categories included in the Framework are not intended to be exhaustive or to cover all possible situations or remediation options for borrowers who may require compensation or other remediation for financial injury. 2. Will the regulators issue updates to the Framework periodically The OCC and FRB do not plan to make updates to the Framework. We recognize that the independent consultants may identify other situations or remediation options that are not covered in the Framework. In those cases the independent consultants may recommend other remediation or compensation for the servicers to use in preparing their remediation plans which will be subject to regulator approval. 3. Will the regulators issue updates to these Frequently Asked Questions periodically The OCC and FRB intend to update these Frequently Asked Questions FAQs as appropriate. 4. Can a borrower get remediation under more than one category in the Framework Borrowers who suffered one of the injuries in categories 1 through 4 will only receive the .

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