HMDA Partial Exemption Resources

HMDA Partial Exemption Resources

Adam Witmer
HMDA

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.

Agencies Release CRA Schedules and Examinations from August 2018

Adam Witmer
CRA

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

Federal Reserve Webinar on Complaint Management

Adam Witmer
Compliance Management

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.

NCUA Guidance Regarding CDD & UBO Compliance

Adam Witmer
Regulatory Update, BSA

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.  

Using a Credit Score Disclosure in Lieu of the Adverse Action Notice

Using a Credit Score Disclosure in Lieu of the Adverse Action Notice

Adam Witmer
Adverse Action, FCRA, Regulation B

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).

OCC Solicits Comments on Modernizing CRA Regulations

Adam Witmer
Regulatory Update, CRA

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.

2019 Regulation Z Thresholds

Adam Witmer
Regulatory Update, Regulation Z

On August 27, 2018, the CFPB published a number of annual threshold adjustments to Regulation Z in the Federal Register.  Effective January 1, 2019, the final rule implements the Truth in Lending Act and satisfies the CFPB’s requirement to calculate annually the dollar amounts for several provisions in Regulation Z.   The 2019 threshold adjustments to Regulation Z are as follows:

The Required Deposit Disclosure for CD Secured Loans

Adam Witmer
Regulation Z

When reviewing deposit secured loans, one of the most common audit violations relates to the “required deposit” disclosure.  This lower risk finding is often found in audit and exam reports because it is a fairly common finding and is extremely easy to identify - known as “low hanging fruit.”  Financial institutions can ensure they don’t fall victim to this easy to avoid issue by fully understanding the rules for the required deposit disclosure.

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