All in Regulatory Update

HMDA Changes Coming & Comments Due

Adam Witmer
HMDA, Regulatory Update

We received a question this week about when to expect more HMDA changes.  That’s right, more HMDA changes are on the horizon, but we really don’t know when to expect them.  As we reported back in May of 2019, the CFPB has issued two things that could result in more HMDA changes: 1) a Notice of Proposed Rulemaking as well as 2) an Advance Notice of Proposed Rulemaking. This article provides a summary of the possible changes, what to look for, and a reminder that comments on both potential changes are due on October 15, 2019.

Flood Program Set to Expire September 30 - What to do?

Adam Witmer
Regulatory Update, Flood

As the twelth exetension of the National Flood Insurance Program is set to expire on September 30, 2019, financial institutions must again hold their breath (no pun intended) to see if Congress yet again kicks the can down the road by renewing the program one more time. While we at the Compliance Cohort will be sure to keep you up-to-date with any changes to the Flood program, you may be wondering what you should do if the Flood program does, in fact, expire. Check out this article for guidance on what your financial institution should do if the flood program were to expire: https://www.compliancecohort.com/blog/what-to-do-if-the-nfip-expires

NCUA Speech Says NCUA Needs Greater Compliance Enforcement

Adam Witmer
Regulatory Update

In a speech prepared for delivery on September 10, 2019, NCUA Board Member Todd Harper gave a speech at the Women in Housing and Finance Policy Lunch. Of interesting note for compliance professionals - especially those in credit unions regulated by the NCUA - is that Mr. Harper explained that he believes there is a need for improved consumer protection examinations and enforcement. Specifically, Mr. Harper explained that…

FinCEN Launches New Division

Adam Witmer
BSA, Regulatory Update

The Financial Crimes Enforcement Network (FinCEN) recently (8/28/19) launched a new Global Investigations Division (GID), which will be responsible for implementing targeted investigation strategies rooted in FinCEN’s unique authorities under the Bank Secrecy Act (BSA) to combat illicit finance threats and related crimes, both domestically and internationally. According to the FinCEN release, GID will leverage FinCEN’s BSA authorities, including Section 311 of the USA PATRIOT Act, to investigate and target terrorist finance and money laundering threats, and GID will work more closely with foreign counterparts to coordinate actions against such threats when appropriate. FinCEN also states that GID will

Flood Exam Manual Updated for Private Flood Insurance Rules

Adam Witmer
Regulatory Update, Flood

The Federal Financial Institutions Examination Council recently (8/22/19) updated their Flood Exam manual to reflect the new requirements for mandatory acceptance of private flood insurance. Mandatory acceptance of private flood insurance was mandatory in July of 2019. If your organization is looking for more information on this now required rule, be sure to take a look at our premium course on private flood insurance at https://www.compliancecohort.com/video-webinar-private-flood-insurance-2019-final-rule. Read more on this article to get a link to the updated exam procedures.

FFIEC Announces 2018 HMDA Data

Adam Witmer
Regulatory Update

On August 30, 2019, the Federal Financial Institutions Examination Council (FFIEC) announced the availability of HMDA data for 5,683 U.S. financial institutions. This data comes from HMDA reporters including banks, savings associations, credit unions, and mortgage companies. The release includes

FinCEN Advisory on Fentanyl and Other Synthetic Opioids

Adam Witmer
BSA, Regulatory Update

On August 21, 2019, the Financial Crimes Enforcement Network (FinCEN) issued an advisory (FIN-2019-A006) to alert financial institutions to possible schemes related to the trafficking of fentanyl and other synthetic opioids.  FinCEN explains that this new advisory will assist financial institutions in detecting and reporting suspicious activity, ultimately making it harder and more costly for criminals to (i) commit crimes related to the trafficking of synthetic opioids; (ii) hide and use their illicit money; and (iii) continue fueling the opioid epidemic that is currently occurring in the United States. 

Fin-2019-A006 highlights the

Oh HEMP!!! -NCUA Issues Guidance on Serving Hemp Businesses

Adam Witmer
BSA, Regulatory Update

On 8/19/19, the NCUA issued guidance for federally insured credit unions on how they can serve lawfully operating hemp businesses.  As the 2018 Farm Bill made a number of changes to how hemp is treated under federal law, some credit unions have lawfully operating hemp businesses within their fields of membership.  The NCUA explains that credit unions may provide the customary range of financial services for business accounts, including loans, to lawfully operating hemp related businesses within their fields of membership.

In the guidance, the NCUA explains that

URLA Implementation Delayed

Adam Witmer
Regulatory Update

As we explained before, Fannie Mae & Freddie Mac (the GSEs) announced in June 2019 that the optional use period for the new version of the Uniform Residential Loan Application (URLA) and automated underwriting system (AUS) implementations would be postponed. In a more recent release, the GSEs explained that they have now been directed to make specific modifications to the redesigned URLA, which is going to delay the February 1, 2020 implementation date. The following changes will be made to the redesigned URLA:

CFPB Updates TRID FAQs Again

Adam Witmer
Regulation Z, TRID, Regulatory Update

The CFPB has again updated the TRID FAQs on their website. This update incorporates five new questions and answers relating to providing loan estimates to consumers. As has been the case with the previously released FAQs, these five new questions don’t really tell us anything we didn’t already know. That said, we will be including a review of these FAQs in our 3Q 2019 Quarterly Compliance Update program (planned to be released sometime in October 2019.

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