CIP Requirements for Business Account Signers

Adam Witmer
BSA

CIP requirements for business account signers can be a confusing subject for some.  While it would seem natural to require CIP for anyone opening an account, that isn’t technically what the rules require, especially when it comes to business accounts.  Therefore, let’s take a deep dive into the CIP requirements and how they apply to business account signers.

Regulation B 30 Day Rule

Adam Witmer
Adverse Action, Regulation B

When a financial institution receives a request for a loan, they are required to respond to that applicant within a certain amount of time to advise them of their credit decision.  That time, however, can vary based on the specific situation and/or financial institution, which has left many compliance professionals confused as to what actually is required. Therefore, let’s take a quick look at the rules and break down what they mean.

BSA Requirements for Privately Owned ATMs

Adam Witmer
BSA

Privately owned ATMs - i.e. ATMs that are not owned by a bank - is a topic that seems to be gaining traction with examiners during BSA exams.  Therefore, it is important for financial institutions to understand their requirements in regards to customers who operate privately owned ATMs. This article takes a look at what is a privately owned ATM is, what risks are associated with them, and how financial institutions can manage privately owned ATM relationships.

HMDA Relief for Community Banks and Credit Unions

Adam Witmer
HMDA, Regulatory Update

After passing through Congress on Tuesday, President Trump today signed into law S.2155, known as the Economic Growth, Regulatory Relief, and Consumer Protection Act.   This banking reform bill, introduced by Idaho Sen. Mike Crapo in November of 2017, does a number of things to undo the burdens placed on smaller financial institutions by the Dodd-Frank Act. One of those things relates to the new fields that were required under the Home Mortgage Disclosure Act (HMDA) beginning on January 1, 2018.

Regulatory Relief for Community Banks and Credit Unions

Adam Witmer
Regulatory Update

Earlier today, President Trump signed into law a major rollback of regulations.  S.2155, known as the Economic Growth, Regulatory Relief, and Consumer Protection Act, was passed by the House on Tuesday, and passed by the Senate over two months ago.  This banking reform bill, introduced by Idaho Sen. Mike Crapo in November of 2017, does a number of things to undo the burdens placed on smaller financial institutions by the Dodd-Frank Act.  

New SCRA Notice

Adam Witmer
Regulatory Update

At the end of the first quarter of 2018, HUD posted a revised SCRA notice which is sent to all delinquent mortgage borrowers.  This revised notice is the one that must be delivered between the 32nd and 45th day after a loan goes into default. The recent revision was made to reflect the extended protection from foreclosure which was adopted as part of the National Defense Authorization Act of 2018.  

FinCEN Delays UBO Requirements for Automatic Renewals

Adam Witmer
BSA, Regulatory Update

On May 16, 2018 - just five days after the new customer due diligence (CDD) rules requiring the identification and verification of ultimate beneficial owners (UBOs) went into effect - FinCEN issued a temporary ruling that delays parts of the new requirements for financial institutions.  FinCEN’s ruling, known as FIN-2018-R002, provides a 90-day limited exception for financial institutions in regards to products and services that automatically rollover or renew, such as loan accounts and certificates of deposit (CDs), that were established before the May 11, 2018 deadline for the new rules.

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