Welcome to the Compliance Cohort. We are a group of compliance professionals working to make compliance easier. Our goal is to take complex compliance concepts and put them in simple terms that apply to the real world. We are glad you have found us and look forward to collaborating in the future.
If you haven't done so already, make sure you sign up for our free membership where you get access to many member-only videos, articles, and other resources.
In this Compliance Clip (video) Adam discusses the compliance rules to look out for when reviewing advertisements and marketing material related to loans. As the consequences of violating lending advertising compliance rules can be significant, it is imperative that financial institutions know what to look for in their lending marketing and advertising material. A transcript of this video is now available.
Our brand new class Lending Advertising Requirements class is now available in our store. This program takes a deep dive into the rules and regulations pertaining to lending advertising. Our Lending Advertising Requirements program includes discussions on some of the challenges financial institutions face with ensuring compliance with marketing or advertisement of loan products, dives into the advertising rules of Regulation Z (for both closed-end and open-end credit), reviews a number of potential fair lending pitfalls, and discusses how some rules, like UDAAP, RESPA Section 8, and even the Fair Housing Act apply to loan advertisements. This program would be good for compliance professionals, marketing team members, lenders, auditors, and anyone else who works with advertising for loans. To learn more about our Lending Advertising Requirements program, go to www.compliancecohort.com/lending-advertising-requirements.
On April 24, 2024, the CFPB published an edition of Supervisory Highlights describing the agency’s actions to combat junk fees charged by mortgage servicers, as well as other illegal practices. The CFPB found that servicers are charging illegal junk fees, such as prohibited property inspection fees; sending deceptive notices to homeowners; and violating loss mitigation rules that help struggling borrowers stay in their homes.
On April 22, 2023, coinciding with the Earth Day celebration, FinCEN issued a press release to remind financial institutions to remain vigilant in identifying and reporting suspicious activity related to environmental crimes. According to FinCEN, environmental crimes frequently involve transnational criminal activity related to several of FinCEN’s Anti-Money Laundering and Countering the Financing of Terrorism (AML/CFT) National Priorities, including corruption, fraud, human trafficking, and drug trafficking.
Our Fair Lending Bootcamp is currently on sale for $100 off the regular price. This program, which is designed as a full-day virtual seminar, takes an in-depth look at what financial institutions need to consider in regards to fair lending. The program includes an introduction to fair lending, a review of Regulation B, a look at some of the applicable aspects of the Fair Housing Act, and a review of fair lending risk indicators. The program even discusses a few fair lending hot topics. The full curriculum for our Fair Lending Bootcamp can be found at www.compliancecohort.com/fair-lending-bootcamp.
On April 15, 2024, FinCEN, in close coordination with the Department of State’s Diplomatic Security Service (DSS), issued a Notice to financial institutions on fraud schemes related to the use of counterfeit U.S. passport cards. The Notice provides an overview of typologies associated with U.S. passport card fraud, highlights select red flags to assist financial institutions in identifying and reporting suspicious activity, and reminds financial institutions of their reporting requirements under the BSA.
On April 8, 2024, the CFPB published an edition of Supervisory Highlights to share key findings from recent examinations about continuing accuracy problems in the credit reporting system. The CFPB found that consumer reporting companies failed to ensure the accuracy of credit reports and that furnishers failed to correct false or fraudulent information sent to consumer reporting companies.
In this Compliance Clip (video), Adam reviews the LE and CD signature requirements of Regulation Z. As you will see, Regulation Z provides a few options for applicant signatures, but also has a few requirements that must be met. A transcript of this video is now available.
On April 5, 2024, the CFPB issued a report finding that more borrowers paid “discount points” upfront as overall interest rates rose. According to the CFPB, the percentage of homebuyers paying discount points roughly doubled from 2021 to 2023.
On April 4, 2024, the Federal Reserve System published its First Issue of Consumer Compliance Outlook for 2024. Consumer Compliance Outlook is the agency’s publication focusing on consumer compliance topics.
