Yesterday, 2/12/19, the CFPB released their list of rural and underserved counties.  That list, which can be exported to a PDF, CSV, or an Excel file, can be found here.   In conjunction with updating this list, the CFPB has also updated its “Rural or Underserved Areas Tool” which can be used to provide a safe harbor determination that a property is located in a rural or underserved area.  The tool provides more detail than the county list because the tool includes both locations that are rural because they lie in a non-urban census block as well as locations that are in rural counties while the list only reflects rural status only at the county level.

We understand that this information isn’t the most exciting of information, but it is important to understand how this information impacts community banks and credit unions.  Specifically, the updated rural and underserved information applies to…

Money Laundering 101

In this Compliance Clip (video), Adam provides an overview of money laundering and gives a big picture illustration of how it applies to financial institutions. This foundational explanation of money laundering gives a great practical example of how money laundering can occur and discusses the three steps illicit “actors” use to launder money in the US financial system. This clip would be a great training resource for anyone who is new to BSA to help them understand what money laundering is. In fact, Adam took these slides directly from our BSA Bootcamp, which is a 3 1/2 hour video webinar that provides a foundational overview of all BSA rules and regulations. For more foundational BSA training just like this, our BSA Bootcamp is available in our store here:

On February 12, 2019, the FDIC extended the comment period related to the Request for Information (RFI) on the Deposit Insurance Application Process from February 11, 2019, to March 31, 2019.  The Financial Institution Letter (FIL-7-2019) announcing this extension can be found here.

An interesting note on this is that the original comment period for this RFI ended on February 11, 2019.  Upon reviewing the comments received on the FDIC’s website, it appears that only ten (10) comments have been received as of the date of the writing of this article.  Therefore, it appears that the FDIC has extended the comment period in hopes of obtaining more comments on this topic.

Comments on the RFI can be submitted (and read) here.

While the revised HMDA rules have been in place for just over a year now, we are finding that a number of financial institutions are still struggling with a few of the quirks of the new rules.  Specifically, one question we have seen a few times in recent months is this: Is a spec home HMDA reportable? To fully understand the answer to this question, we need to first discuss how the changes to the 2018 HMDA rules relate to this topic.  You see, under the old HMDA rules, spec homes were…

Do you enjoy your membership at the Compliance Cohort? If so, we’d love to hear from you.

You see, we are redoing a few things on our website and are looking for a few member testimonials to be used on our home page and in other marketing material. If you are interested in providing feedback about your membership, you can do so here:

Members like you are the reason we do what we do.

HMDA Exemption Property Address

In this Compliance Clip (video), Adam discusses how the Property Address data point applies to the partial exemption. Specifically, he provides guidance on how exempt institutions are to report the street, city and state when they are listing the state data field as part of the Property Location data point. As you would expect, this is a fairly complex topic that has caused quite a bit of confusion, so Adam attempts to break the rules down into easy-to-understand layman’s terms.

If you are an exempt reporter or plan to use the partial exemption for your 2019 data, be sure to check out our Compliance Class (video webinar) on the HMDA partial exemption in our store. Everything you need to know about the partial exemption is covered in less than an hour and includes a comprehensive training manual for reference and a Q&A of some more complex questions relating to the partial exemption. View the Compliance Class (video webinar) at

I have spent a bit of time studying comedy.  I’m no expert by any means, but I’m always intrigued by the details of how things work, and comedy is no exception.  I figure that once I understand how something like comedy works, I will be able to better use it and appreciate it.

When we look at the art of comedy, there is one well-known element that seems to be….

(Click here to see how this post relates to the new TRID FAQs - and we promise it does!)

Over the years, we have seen a number of questions relating to how Regulation E error resolution rules relate to pending transactions that have not yet settled to a customer’s account.  The challenge that many bankers face is a customer will call in to dispute a transactions they see on their account as a “memo post,” but since the transaction is pending, it may never actually post to the account or will be finalized in an amount different than the original “memo post” amount. For bankers, this is challenging because…

HMDA Exemption for Large CRA Reporters

Adam uses this Compliance Clip (video) to talk about one of the nuances of the CFPB’s Interpretive and Procedural Rule regarding the HMDA partial exemption. Specifically, this video explains how the property address and property location data points apply to large CRA reporters who also qualify for the HMDA partial exemption. The answer might not be exactly what you think…. or even what the CFPB intended.

Two sets of comments are due next week.

First, Tuesday, February 5 marks the last day to comment regarding the proposal to increase the appraisal threshold for residential real estate transactions from $250,000 to $400,000.  The proposed rule provides thirteen questions for which the agencies are seeking comment.

Secondly, comments regarding the Regulation CC proposal must be in by Friday, February 8, 2019.  This request for comment does two things as the proposal would first implement new changes to the Expedited Funds Availability Act and also provides an additional opportunity for public comment on the 2011 funds availability proposal that was never finalized.