Welcome to the Compliance Cohort. We are a group of compliance professionals working to make compliance easier. Our goal is to take complex compliance concepts and put them in simple terms that apply to the real world. We are glad you have found us and look forward to collaborating in the future.
If you haven't done so already, make sure you sign up for our free membership where you get access to many member-only videos, articles, and other resources.
Adam uses this Compliance Clip (video) to talk about one of the nuances of the CFPB’s Interpretive and Procedural Rule regarding the HMDA partial exemption. Specifically, this video explains how the property address and property location data points apply to large CRA reporters who also qualify for the HMDA partial exemption. The answer might not be exactly what you think…. or even what the CFPB intended.
Two sets of comments are due next week.
First, Tuesday, February 5 marks the last day to comment regarding the proposal to increase the appraisal threshold for residential real estate transactions from $250,000 to $400,000. The proposed rule provides thirteen questions for which the agencies are seeking comment.
Secondly, comments regarding the Regulation CC proposal must be in by Friday, February 8, 2019. This request for comment does two things as the proposal would first implement new changes to the Expedited Funds Availability Act and also provides an additional opportunity for public comment on the 2011 funds availability proposal that was never finalized.
On January 25, 2019, the joint agencies issued a final rule requiring lending institutions to accept “private flood insurance.” This long-awaited rule was mandated by the Biggert-Waters Act and went through two different proposals. One of the biggest challenges the new rule could have created relates to how lenders will determine whether a private flood insurance policy is considered to be in compliance and, therefore, acceptable. To alleviate this challenge, the final rule provides a…
Fair lending continues to be one of the highest risk areas for any creditor. Deficiencies can result in significant penalties, fines, and other enforcement actions. Therefore, each creditor must understand the different types of fair lending violations that could be cited during a fair lending audit or compliance examination. In other words, if a creditor if familiar with what an examiner will be looking for, they will be more likely to self-identify and correct the issue before it becomes a significant exam violation.
Though estimate tolerance rules have been around before TRID, “good faith,” tolerances, and refunds/cures seem to still be a challenge for many lenders and creditors. This is concerning as tolerances/cures are one of the higher-risk areas (like rescission) that creditors really need to ensure they are doing appropriately as deficiencies can result in significant fines, penalties, and enforcement actions.
In reviewing the challenges related to calculating “good faith” and providing appropriate refunds/cures, it appears that there still seems to be quite a bit of confusion relating to how a creditor must calculate tolerances in the 10% tolerance bucket.
From now through Thursday January 24, 2018, we are offering $50 off of our newest Quarterly Compliance Update video webinar. (View pricing/discount options here.)
If you are a compliance professional wanting to keep up-to-date on regulatory changes, then this program was designed for you. Each Quarterly Compliance Update class is designed to provide you with the need-to-know information about what regulatory activity took place during the prior quarter, which is an essential element of an effective compliance management system. Specifically, our 4th Quarter Compliance Update class is covers regulatory activity that took place during the months of October, November, and December of 2018.
This Compliance Class can be completed in 1.5 hours and is presented in our standard “virtual classroom” approach where a video displays an instructor standing in front of presentation slides - just like you would have at a live seminar. In addition to the video, each Quarterly Compliance Update class includes a comprehensive manual that can be used for taking notes, getting further information, and retaining the information as a reference tool.
You can view the entire curriculum and learn more about this Quarterly Compliance Update video webinar here.
In this Compliance Clip (video), Adam discusses how the beneficial ownership rules apply to schools and school corporation. Surprisingly, the application isn’t as simple as you might think.
In early January 2019, the NCUA released a letter (19-CU-01) to credit unions outlining their primary areas of supervisory focus for 2019. In their letter, the NCUA explained that the extended exam cycle introduced in 2017 would be fully implement in 2019, examiners will continue to increase offsite work, and that streamlined procedures and risk-focused exams will continue to be utilized, as applicable. For 2019, the NCUA has outlined a number of supervisory priorities. While many of these priorities are of a safety and soundness focus, the NCUA outlines two priorities that compliance professionals should be aware of.
As more and more examiners are expecting fair lending training for the Board of Directors, it is important to ensure that training efforts meet the needs of directors of the Board. Well effective board training can be similar to training for other employees of the financial institution, it is important to understand several unique factors necessary for effective director training. The following three tips can be used for providing fair lending training to the Board of Directors.
Today (1/11/18) is the last chance to enter for a chance to win enrollment to our upcoming class/video webinar on the 4th Quarter Compliance Update. This new class will be available within the next few weeks and will cover regulatory activity that took place during the months of October, November, and December of 2018.
To get your chance to win the 4th Quarter, Quarterly Compliance Update class/video webinar for free, just send an email to members@compliancecohort.com that says something like “Please enter me for a chance to win the 4th Quarter Compliance Update.” All entries must be received by 2:00 pm Eastern on Friday, January 11, 2019 as the winner will be chosen shortly after this time.
Read the rest of this article to learn more about this course.
