2019 Threshold for HPML Appraisal Exemption

Adam Witmer
Regulation Z, Regulatory Update

On November 21, 2018, the Agencies announced the 2019 threshold for smaller loan exemption from appraisal requirements for higher-priced-mortgage loans (HPMLs).  The Dodd-Frank Act amended the Truth in Lending Act to add special appraisal requirements for higher-priced mortgage loans, including a requirement that creditors obtain a written appraisal based on a physical visit to the home’s interior before making a higher-priced mortgage loan. The rules implementing these requirements contain an exemption for loans of $25,000 or less and also provide that the exemption threshold will be adjusted annually to reflect inflation increases.

$100 Off the BSA Bootcamp!

Adam Witmer

From now through 12/12/18, we are offering $100 off the BSA Bootcamp! Training for those new to BSA. The BSA Bootcamp! is designed to be a foundational online course on the Bank Secrecy Act and anti-money laundering (AML) rules.  Longer and more comprehensive than a typical webinar, this Compliance Class runs around 3 ½ hours and takes a deep dive into the core elements of BSA rules that any BSA/AML professional should know and understand.  See the full course curriculum and watch an overview video at www.compliancecohort.com/video-webinar-bsa-bootcamp.

What to do if the NFIP Expires?

Adam Witmer
Flood, Regulatory Update

Every couple of years, the National Flood Insurance Program (NFIP) gets set to expire.  This is a result of the way Congress funds the program as the typically only renew the program for a few years at a time.  That is, if they renew the program on time.

Often times, the program is operating at a loss and Congress has a difficult time passing a long-term approval of the program.  When this happens, the program is typically reapproved on a short-term basis, but there are cases where the program expires.

It's almost ready! - BSA Bootcamp Available on Monday

Adam Witmer

Starting next week, we will be releasing our newest Compliance Class: BSA Bootcamp! Training for those new to BSA. This comprehensive training program is designed as a foundational course, covering all of the core BSA requirements a BSA/AML professional needs to know. Running nearly 3 1/2 hours long, this deep-dive program is divided up into three different videos and comes with a comprehensive manual to follow along, take notes with, and keep as a reference tool.

While this program is designed as a foundational class to bring those up to speed who are new to BSA, this class isn’t just for new BSA Officers. This class would be great for BSA back-ups, auditors, those who oversee the BSA function, those who specialize in just a single area of BSA - and even those who are seasoned in BSA and looking for a refresher course that covers core BSA/AML elements.

Be sure to check our store Monday for an early registration discount and watch for more information about our newest Compliance Class: BSA Bootcamp! Training for those new to BSA.

Oh yeah, and congratulations to Anne S. who won a free subscription to the BSA Bootcamp from our give-away last week!

Agencies Propose Increase to Residential Appraisal Threshold

Adam Witmer
Regulatory Update

On November 11, 2018, the federal agencies (FDIC, Federal Reserve, and OCC) released a notice of proposed rulemaking and request for comment.  In the release, the agencies are inviting comment on a proposed rule to amend regulations requiring appraisals for certain real-estate related transactions.  The proposed rule would increase the threshold level at or below which appraisals would not be required for residential real estate-related transactions. The proposed rule would increase the threshold from $250,000 to $400,000.

HMDA Loan Amount For Counteroffers

Adam Witmer
HMDA

The new HMDA rules have created a whirlwind of challenges for HMDA reporters as reporters have had to learn which knowledge they could retain from the prior rules and which knowledge they had to adjust - not to mention the new elements that had to be learned.  The reality is that it takes time to get all of the “kinks out” when learning a new, especially one that is as complicated as HMDA and Regulation C. A prime example of the challenges that are created due to the implementation of a new rule is the HMDA loan amount when there has been a counteroffer.

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