All in Regulatory Update

CFPB Releases HMDA Filing Instruction Guide for 2019

Adam Witmer
HMDA, Regulatory Update

On October 23, 2018, the CFPB released the Filing Instruction Guide (FIG) for data collected in 2019.  This guide comes less than two months after the most recent version of the guide (August 2018), but is designed to be used for data collected during 2019.  The FIG is considered to be a “technical resource to help financial institutions file HMDA data collected in 2019 and reported in 2020.”

Agencies Release New Appraisal FAQs

Adam Witmer
Regulatory Update

On October 16, 2018, the OCC, Federal Reserve, and FDIC published new FAQs regarding appraisals and evaluations for real estate transactions.  These FAQs clarify existing regulatory requirements and guidance that is found in two previous issuances:the 2010 Interagency Appraisal and Evaluation Guidelines and the 2016 Interagency Advisory on Use of Evaluations in Real Estate-Related Financial Transactions.

OCC Updates Three Booklets

Adam Witmer
Regulatory Update

On October 15, 2018, the OCC issued a Bulletin (2018-38) announcing the updating of three booklets: “Agricultural Lending,” “Oil and Gas Exploration and Production Lending,” and “Trade Finance and Services.”  These booklets are part of the Comptroller’s Handbook and are used by examiners for their supervision and examinations of these areas.

Interagency Statement on Sharing of BSA/AML Resources Among Financial Insittutions

Adam Witmer
Regulatory Update, BSA, Compliance Management

On October 3, 2018, the main federal regulators, along with FinCEN, released a statement regarding instances in which banks and credit unions may decide to enter into collaborative arrangements to share resources to manage their Bank Secrecy Act (BSA) and anti-money laundering (AML) obligations more efficiently and effectively.  While this guidance may not be beneficial for a majority of financial institutions, this may be beneficial for very small institutions with a low-risk profile and less-complex structures, or those institutions who are owned by the same organization.

Agencies Grant CIP Exemption for Insurance premium Finance Loans

Adam Witmer
BSA, Regulatory Update

On September 28, 2018, FinCEN, the OCC, Federal Reserve, FDIC, and NCUA released joint guidance which grants financial institutions an exemption from CIP requirements for loans extended to customers to facilitate purchases of property and casualty insurance policies.  The justification for this exemption is based on the fact that these types of loans present a low risk of money laundering due to their very specific purpose. Those entities that extend loans to customers for such purposes should…

A Checklist of TRID 2.0 Changes

Adam Witmer
Regulation Z, Regulatory Update, TRID

As the October 1, 2018 compliance date of TRID 2.0 is quickly approaching, it is important for each financial institution to ensure that all applicable changes to the integrated disclosure rules have been both understood and effectively implemented.  Released on July 7, 2017, the 2017 final rule (known as TRID 2.0) amends and clarifies certain mortgage disclosure provisions implemented in Regulation Z. These changes are required for any application received on or after October 1, 2018.

FinCEN Advisory on High-Risk Customers

Adam Witmer
Regulatory Update, BSA

On September 21, 2018, FinCEN released an advisory on the FATF-identified jurisdictions with AML/CFT deficiencies.   This advisory, known as FIN-2018-A004, relays information to US financial institutions regarding countries the Financial Action Task Force (FATF) has identified as having deficiencies.  FATF is an intergovernmental body comprised of…

FDIC Seeks Comment on Retiring Financial Institution Letters

Adam Witmer
Regulatory Update

On Monday, September 10, 2018, the FDIC released a Financial Institution Letter (FIL-46-2018) seeking comment on a proposal to retire certain FILs to an inactive status.  Specifically, the proposal is targeting 374 of the 664 risk management supervision-related FILs issued over nearly two decades that are considered to either be outdated or that convey regulations or other information that is still in effect but available elsewhere on the FDIC’s website.  

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