NEW RESOURCE - List & Links of Banking Regulations

Adam Witmer

The next time you log in to your membership dashboard at www.compliancecohort.com, you will see that we have added a new feature for our members: a list of banking regulations. The goal of this resource is to provide you a compiled list of most of the banking regulations you may need to do your job. While it is our goal to translate complex regulations into layman’s terms in our member-only articles and Compliance Clips (videos), we understand that there will be times where you need to look something up. It is our hope that this new resource will help you find what you are looking for a bit faster.

You can access our list of banking regulations through your membership dashboard, or by going to https://www.compliancecohort.com/banking-regulations-list.

Lessons Learned from USAA - Reg E & UDAAP

Adam Witmer
Regulation E, Regulatory Update, UDAAP

On 1/2/19, new CFPB director Kathleen Kraninger signed a consent order with USAA Federal Savings Bank.  While the consent order outlines millions of dollars in restitutions and penalties, the order provides financial institutions with fairly detailed insights on a number of Regulation E violations identified by the Bureau.  As Regulation E applies to all financial institutions regardless of their regulator, this consent order can be used as a learning tool for appropriately complying with the Regulation.

Specifically, the USAA consent order outlined six main deficiencies that resulted in either a violation of Regulation or a UDAAP violation, or both, including…

Back-Up BSA Officer Training Expectations

Adam Witmer
BSA

Bank Secrecy Act rules and regulations are complex, challenging, and at times, overwhelming.  Not only must a BSA/AML professional be able to complete daily tasks like reviewing transactions and filing reports, but they also must be a knowledge expert in the many areas of the Bank Secrecy Act.  For this reason, many financial institutions employ professionals who specialize in the Bank Secrecy Act and anti-money laundering rules and regulations.

But what happens when this specialist leaves the financial institution?

Unfortunately, financial institutions sometimes find themselves in a difficult situation when a BSA professional gets promoted or leaves their organization.  This is where having continuity in BSA/AML knowledge in a financial institution is important. In fact, the FFIEC BSA Exam manual states that a BSA program should have continuity despite changes in employees.  In order to do this, cross-training of employees in BSA & AML rules is essential.

2019 HMDA Exemption Threshold

Adam Witmer
HMDA, Regulatory Update

On December 31, 2018, the CFPB adjusted the HMDA exemption threshold from $45 million to $46 million.  The adjustment is based on the 2.6 percent increase in the average of the CPI-W for the 12-month period ending in November 2018. Therefore, banks, savings associations, and credit unions with assets of $46 million or less as of Dec. 31, 2018, are exempt from collecting data in 2019.

TRID 2.0 Total of Payments Tolerance

Adam Witmer
TRID, Regulation Z

The changes made by TRID 2.0 were interesting.  On one hand, a few things made significant changes to the way we have always done things.  On the other hand, however, the majority of changes were fairly minor in nature or didn’t seem to affect the majority of financial institutions.  One question we have received a few times relates to the new TRID 2.0 rules for total of payment tolerances.  When TRID 2.0 was first announced, this seemed to be one of biggest changes included in the rules. Now that TRID 2.0 is in affect, however, some may be wondering what all of the fuss was about relating to the TRID 2.0 tolerances for total of payments.

OCC Releases Fall 2018 Semi-Annual Risk Perspective

Adam Witmer
Regulatory Update

Earlier this month (12/3/18), the OCC released their semi-annual risk perspective for the fall of 2018.  The report covers risks facing national banks and federal savings associations based on data as of June 30, 2018. The report presents information in five main areas: the operating environment, bank performance, special topics in emerging risk, trends in key risks, and supervisory actions. It focuses on issues that pose threats to those financial institutions regulated by the OCC and is intended as a resource to the industry, examiners, and the public. The report also includes several compliance and BSA-focused perspectives on trending challenges facing OCC-regulated banks.

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