The Difference Between MLA & SCRA

The Difference Between MLA & SCRA

Adam Witmer
SCRA, MLA

In this Compliance Clip (video), Adam explains the different compliance requirements between MLA & SCRA and gives a general overview of each law. (Note: The ending on this is terrible as Adam never quite knows how to end his videos!)

OCC Bulletin Reminds of Confidentiality Requirements

Adam Witmer
Regulatory Update

On March 25, 2019, the OCC released Bulletin 2019-15 as a reminder to supervised banks that certain nonpublic OCC information generally cannot be disclosed.  In the bulletin, the OCC explains that reports of examination and other nonpublic OCC information are the property of the OCC. Except in very limited circumstances, a bank may not disclose this information without the prior written permission of the OCC. This prohibition applies to any portion of a report of examination, supervisory correspondence, and any representations concerning the report or supervisory correspondence, or their findings, including the assigned CAMELS rating. Any unauthorized disclosure or use of nonpublic information may be subject to criminal penalties.

FFIEC Releases 2019 HMDA GIR Guide

Adam Witmer
HMDA, Regulatory Update

On March 25, 2019, the CFPB announced the availability of the FFIEC 2019 HMDA Getting it Right (GIR) Guide.  Updated each year, the GIR guide is a valuable resource for assisting all institutions in their HMDA reporting. It includes a summary of responsibilities and requirements, directions for assembling the necessary tools, and instructions for reporting HMDA data.

The full GIR guide can be found at…

The 2019 edition is effective January 1, 2019, and applies to 2019 HMDA data that must be submitted by March 1, 2020.  This updated edition reflects amendments made to HMDA by the Economic Growth, Regulatory Relief, and Consumer Protection Act and the 2018 HMDA interpretive and procedural rule issued by the Consumer Financial Protection Bureau.

RESPA Section 8 Joint Advertising

Adam Witmer
RESPA

The rules surrounding RESPA Section 8 prohibitions against kickbacks and unearned fees have been around for decades.  These rules, however, seem to be easily forgotten and overlooked by lenders and Realtors alike. In fact, the regulators often tend to go through dry spells where they don’t issue any public enforcement actions relating to Section 8 violations, though it is doubtful that such violations don’t continue to occur.  The reality is that the RESPA Section 8 prohibitions still exist and the we have even seen some recent…

Feedback Requested for "Top" Violations

Adam Witmer

We are looking for feedback on the top violations you are seeing in the world of regulatory compliance.  This information will help Adam prepare for an upcoming presentation titled “60 Violations in 60 Minutes.”  We are looking for any and all “top” violations that compliance officers, auditors, and/or examiners are seeing.  Any and all feedback is welcome and thank you in advance!

To provide your feedback on the “top” violations, go to our survey here or go to https://www.compliancecohort.com/top-violations-survey

1Q 2019 Compliance Update Class to be Available Mid to Late April

Adam Witmer

Coming off a year of some significant regulatory changes like TRID 2.0, HMDA 2.0, and the BSA Beneficial Ownership rule, you might think that 2019 should be a slower year for regulatory changes.  Should be. In reality, 2019 is already proving to be just as complex and fast moving as 2018 was.  From trend-setting enforcement actions to new rules like private flood insurance, the first quarter of 2019 has had a plethora of changes.

As we have done in 2018, we will again release a training program to review all of the significant changes from the prior quarter that compliance professionals need to be aware of.  Our 1Q 2019 Compliance Update program will be available for purchase sometime in April, so be sure to watch for upcoming communications relating to this valuable training program. Click here to see what is on the agenda for this program…

Redlining & Branching Networks

Redlining & Branching Networks

Adam Witmer
Fair Lending

In this Compliance Clip (video), Adam takes a look how a financial institution’s branching network could have an impact on redlining risk. The clip provides two visual maps as Adam reviews what redlining would look like visually, when it comes to a branching network.

FFIEC Updates Exam Report Standards

Adam Witmer
Regulatory Update

On March 6, 2019, the FFIEC issued a joint statement to promote consistency, clarify and ease of reference for the presentation of information in examination reports.  The FFIEC has been working on an Examination Modernization Project - which is aimed at reducing unnecessary regulatory burden on community financial institutions - and this policy statement is aimed to provide consistency upon exam agencies in regards to the structure of examination reports.

FDIC Rescinds Annual Disclosure Requirement

Adam Witmer
Regulatory Update

On 3/18/19, the FDIC finally rescinded their annual disclosure statement requirement.  This rule comes a few months after the October 25, 2018 proposal, and over twenty years after two other agencies rescinded similar guidance due to the internet and availability of such data.  This new final rule rescinds and removes the FDIC’s regulations entitled Disclosure of Financial and Other Information By FDIC-Insured State Nonmember Banks. Once the regulations are removed, state nonmember banks and insured state-licensed branches of foreign banks will no longer be subject to the annual disclosure statement as the information required to be disclosed by this rule is also available publicly through the FDIC’s website.

It should be noted that this rule will become effective on April 17, 2019 - meaning that applicable banks must ensure that the disclosure statement requirements are met for 2019 as the deadline is (at least) March 31 of each year.

Load More