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…

Denial Reasons of Excessive Obligations & Insufficient Income

Denial Reasons of Excessive Obligations & Insufficient Income

Adam Witmer
Adverse Action, Regulation B

This Compliance Clip (video) discusses the difference between two denial reasons found on most adverse action notices: 1) Excessive Obligations in Relationship to Income and 2) Insufficient Income for the Amount of Credit Requested. Adam discusses why most denial forms have these two different, but distinct debt-to-income (DTI) options and explains the best practice for when to use each reason - which might not be what you think.

Adding Force Place Flood Insurance Premium to Loan Amount

Adam Witmer
Flood

When a customer doesn’t pay their flood insurance premiums and allows their flood insurance to lapse, financial institutions are required to force-place flood insurance for an appropriate amount.  While customers who allow their flood insurance coverage to lapse often do so because they can’t or don’t want to pay for such coverage, it can be difficult for financial institutions to collect for the premiums (or cost) of the force-placed flood insurance.

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.  

Early Bird Discount for HMDA Compliance Class to Expire

Adam Witmer

The early bird discount for our Compliance Class on the HMDA partial exemption and the CFPB’s interpretive and procedural rule is ending on Monday, September 17, 2018.  This comprehensive Compliance Class webinar includes: 1) a ready-to-play instructional video, 2) a comprehensive training manual, 3) a step-by-step guide for how to determine eligibility for the partial exemption, 4) an exemption reporting cheat sheet, 5) an executive summary of the rule to share with management or the Board, and 6) a Q&A of frequently asked questions. Those interested in the class can take advantage of an Early Bird special through September 17, 2018 that saves $50 off the regular price and allows early enrollees to submit questions for the final Q&A.

CFPB Releases Sept 2018 Edition of Supervisory Highlights

Adam Witmer
Regulatory Update

On September 6, 2018, the CFPB released their 17th edition of Supervisory Highlights.  This current edition covers supervision activities from the CFPB during the time period of December 2017 through May of 2018.  This current edition shares observation in the areas of auto loan servicing, credit card account management, debt collection, mortgage servicing, payday lending, and small business lending.  The report also shares a number of public enforcement actions taken with supervised backs as well as providing a discussion on recent Bureau rules and guidance.

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