All in Regulatory Update

New Mortgage Servicing Rules and FAQs

Adam Witmer
Regulatory Update

Earlier this month, the CFPB issued a final rule that amends certain parts of the 2016 mortgage servicing rules relating to periodic statements.  This rule revised the timing requirements for services that are transitioning between modified or unmodified periodic statements and coupon books when a consumer enters or exits bankruptcy.  In addition to these rules, the CFPB

2018 HMDA Getting It Right Guide

Adam Witmer
HMDA, Regulatory Update

The FFIEC has finally released an updated HMDA Getting It Right Guide.  The FFIEC release the new guide today, which is the first revision of the guide since 2013.  The new version has been completely revised to reflect the HMDA changes from the 2015 final rule as well as the 2017 amendments that went into effect on January 1, 2018.  

CFPB Request on Supervision Process

Adam Witmer
Regulatory Update

On February 14, 2018, the CFPB issued a request for information on their supervision process.  In a statement, the CFBP stated that they are seeking comments and information from interested parties to assist in assessing the overall efficiency and effectiveness of its supervision program and whether any changes to the program would be appropriate.  This is the fourth such requests by...

FinCEN Updates SAR Form

Adam Witmer
BSA, Regulatory Update

FinCEN recently announced that they will be revising the Suspicious Activity Report.  The new version of the SAR will be available in June of 2018 and will include several changes.  FinCEN is currently in the process of developing and testing the updated SAR and has released some mock-ups of the proposed SAR, though they say that the final SAR may be slightly different.  This is the first round of updates to the SAR form since releasing the new electronic version of the form a few years back.  While we saw changes to the...

CFPB Makes Changes to Prepaid Accounts Rule

Adam Witmer
Regulatory Update

Yesterday, the CFPB finalized some updates to its 2016 prepaid rule.  The original rule put in place some consumer protections for prepaid accounts such as the treatment of funds on lost or stolen cards, error resolution and investigation, upfront fee disclosure, access to account information, and disclosing applicable overdraft features.  Yesterday’s changes adjust requirements for...

CFPB Calls for Feedback

Adam Witmer
Regulatory Update

Yesterday, the CFPB announced that it is issuing “call for evidence to ensure the Bureau is fulfilling its proper and appropriate functions to best protect consumers.”  This call comes just weeks after CFPB management changed where Mick Mulvaney was appointed by President Trump to temporarily run the CFPB after the departure of long-time director Richard Cordray.   The CFPB publication states that the Bureau will...

Payday Rule and CFPB Statement

Adam Witmer
Regulatory Update

On January 16, 2017, the CFPB issued a statement that they intend to reconsider the final Payday Rule which was originally issued on October 5, 2017.  This publication, which came on the effective date of the final rule, explains that the reconsideration will occur through an official rulemaking process.  The CFPB also discusses how compliance with the final rule will be affected by...

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