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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This Compliance Clip (video) discusses one of the more minor changes in TRID 2.0; how to list the purpose for a simultaneous second mortgage. Adam explains the new clarification in TRID 2.0 and the commentary and answers a question from a fellow Cohort member.
On September 6, 2018, the CFPB released their 17th edition of Supervisory Highlights. This current edition covers supervision activities from the CFPB during the time period of December 2017 through May of 2018. This current edition shares observation in the areas of auto loan servicing, credit card account management, debt collection, mortgage servicing, payday lending, and small business lending. The report also shares a number of public enforcement actions taken with supervised backs as well as providing a discussion on recent Bureau rules and guidance.
On Friday September 7, 2018, the Financial Crimes Enforcement Network (FinCEN) granted exemptive relief for covered financial institutions from the obligations of the Beneficial Ownership Rule when a legal entity customer opens a new account as a result of…
On September 5, 2018, the FDIC released their summer edition of their Supervisory Insights publication. The notice of the publication, FIL-44-2018, explained that the current edition features two main articles of interest to examiners, bankers and supervisors.
In this atypical Compliance Clip (video), Adam explains why those who qualify for the HMDA partial exemption will probably want to use it as quickly as possible. He also manages to relate one of his most embarrassing stories to HMDA.
The FDIC and OCC have each released their lists of CRA performance evaluations from August 2018. In addition, these agencies - as well as the Federal Reserve - have released their quarterly schedules of planned CRA evaluations for the 4th quarter of 2018 and the first quarter of 2019. Institutions regulated by the OCC, FDIC, and Federal Reserve can review these schedules to determine whether they are on the planned list of upcoming CRA exams. As we have said before, one of the best
On August 29, 2018, the Federal Reserve hosted a webinar regarding focused on the topic of complaint management titled “Complaints as a Supervisory and Risk Management Tool.” In this webinar, the Federal Reserve provided an overview of their complaint investigation process and provided an overview of what they look for when investigating complaints. While this webinar didn’t provide significantly new information, there were a few takeaways from this training, including some guidance on how to manage complaints on social media.
In August of 2018, the NCUA issued a letter to Credit Union CEOs and Boards of Directors regarding examination guidance for Bank Secrecy Act (BSA) customer due diligence(CDD) and ultimate beneficial ownership (UBO) compliance. The letter (18-CU-02) explained to credit unions that the NCUA has issued examination procedures to field staff regarding the new CDD and UBO rules that went into effect earlier in 2018. The Credit Union Letter included an attached supervisory letter that provides all federally insured credit unions with examination expectations for NCUA examiners regarding conducting reviews of a credit union’s compliance with the new rules.
This Compliance Clip (video) answers the question of whether the FCRA pieces of the AA Notice must be completed every time, or if creditors can combine certain FCRA disclosures with the AA Notice. Adam attempts a new approach to adding a bit of humor to a mundane compliance topic and fails terribly. He makes a promise to never attempt this approach again (unless he is asked).
On August 28, 2018, the Office of the Comptroller of the Currency (OCC) issued an advance notice of proposed rulemaking (ANPR) inviting public comment on ways to modernize the regulations that implement the Community Reinvestment Act (CRA). In their notice (OCC-2018-0008), the OCC is soliciting ideas on how the CRA rules could better achieve the statute’s original purpose, encourage increased lending and investment where it is needed the most, and reduce the burden associated with reporting and evaluating CRA performance. As the OCC plans to share the results of the ANPR with other regulatory agencies, all financial institutions are encouraged to provide comments to the OCC.
