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.
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Welcome to the Compliance Cohort Blog. You will find a number of public articles and videos designed to assist those in banks, credit unions, and mortgage companies with regulatory compliance. In addition to our blog, we provide even more free resources when you join our free Basic Membership. There is no cost to enroll in our Basic Membership where you get:
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In this video, Adam talks about the third type of discrimination recognized by the courts: disparate impact. He explains the main source of this type of discrimination and gives a few examples of what to look for.
On 7/1/2020, the Federal Financial Institutions Examination Council (FFIEC) issued a statement to highlight the risks that will result from the transition away from LIBOR, which is used by the financial industry as a reference rate for many products and instruments like loans, investments, and deposits. In their release, the regulators encouraged financial institutions to continue working toward a transition to alternative reference rates so that financial, legal, operational, and consumer protection risks can be mitigated. While the transition away from the LIBOR will affect some institutions more than others, the regulators state that the impact will affect almost all institutions and, therefore, it would be beneficial for all financial institutions to consider the risks associated with the LIBOR transition.
On March 16, 2020, FinCEN issued a request that financial institutions affected by the COVID-19 pandemic contact FinCEN and their functional regulator as soon as practicable if a COVID-19-affected financial institution has concern about any potential delays in its ability to file required Bank Secrecy Act (BSA) reports. FinCEN also states that institutions seeking to contact them should call FinCEN’s Regulatory Support Section (RSS).
In this potentially embarrassing Halloween special Compliance Clip (video), Adam answers this week’s question dressed as none other than…. well, you will have to watch the video to see. (Yes, Adam is in a costume in this video and if you don’t recognize the character, stick around to the end of the video for an explanation of who it is!) You don’t want to miss this one-of-a-kind video!
In this Compliance Clip (video), Adam answers a question related to which appraisal threshold applies for a consumer-purpose loan secured by two 1-4 family properties (for a bank). As the answer to this might not be what you expect it to be, Adam points out a few of the challenges of the new appraisal thresholds. This video provides a great overview of when the different appraisal thresholds apply to bank loans.
On October 10, 2019 the Consumer Financial Protection Bureau (CFPB) issued a rule which finalizes some parts of its May 2019 Notice of Proposed Rulemaking that we previously reported on. This new final rule extends for two years the current temporary threshold for collecting and reporting data about open-end lines of credit under HMDA. The rule also clarifies partial exemptions from certain HMDA requirements which Congress added in the Economic Growth, Regulatory Relief, and Consumer Protection Act (EGRRCPA).
The CFPB has released the summer 2019 Edition of Supervisory Highlights. In this issue, topics include UDAAPs, auto loans, Supervision, compliance, credit cards, credit reports and scores, debt collection, Fair Credit Reporting Act, mortgage origination. The full version of Supervisory Highlights can be found here.
As you might expect, we will be coving the portions of Supervisory Highlights that relate to compliance professionals in our next Quarterly Compliance Update. You can view the tentative curriculum for our Q3 2019 Quarterly Compliance Update here.
Adam uses this Compliance Clip (video) to explain what BSA is in the banking industry. This video provides a high-level overview of BSA and money laundering, giving a general overview of the rule. For more information on BSA and anti-money laundering laws, take a look at our BSA Basics program at www.compliancecohort.com/bsa-basics.
On July 25, 2019, the CFPB announced an Advance Notice of Proposed Rulemaking (ANPR) seeking information relating to the expiration of the temporary qualified mortgage (QM) provision applicable to certain mortgage loans eligible for purchase or guarantee by the Government Sponsored Enterprises (GSE - i.e. Fannie Mae & Freddie Mac). This provision, also known as the GSE patch, is scheduled to expire no later than Jan. 10, 2021.
As the ANPR states that the Bureau currently plans to allow the GSE Patch to expire around January 2021, financial institutions…
On December 6, 2018, the CFPB announced a settlement with State Farm Bank which is a federal savings association headquartered in Bloomington, Ill. In their consent order, the Bureau explains that they found that State Farm Bank violated the Fair Credit Reporting Act, Regulation V, and the Consumer Financial Protection Act of 2010 by…
