Federal Reserve Releases Supervision & Regulation Report

Adam Witmer
Regulatory Update

On May 10, 2019, the Federal Reserve released their semi-annual report on supervision and regulation.  This report, which summarizes banking conditions and he Fed’s supervisory and regulatory activities, runs 44 pages long and includes two appendices.  The “Supervisory Developments” section of the report outlines the Fed’s examination process by explaining the examination process and outline key safety and soundness concerns.

Privacy Policy Definition Section in Italics?

Adam Witmer
Privacy

As the current privacy policy model form used as the safe harbor under Regulation P has been around for nearly a decade now, it is easy to just assume that all the kinks with the implementation of that model form have been worked out and your privacy policy is in compliance.  While this is the case the majority of times, sometimes certain things get lost over time.

CFPB Releases Factsheet on TRID Applicability for Assumptions

Adam Witmer
Regulatory Update, TRID

On May 1, 2019, the CFPB issued a Fact Sheet discussing TRID applicability for assumptions.  This six-page document answers the question of whether Loan Estimates (LEs) and Closing Disclosures (CDs) are required for assumptions and contains two main parts: 1) a flowchart and 2) a narrative discussion. The flowchart is a quick reference that highlights the major questions to be answered when determining if a Loan Estimate and Closing Disclosure are required for the assumption transactions described above. The narrative discussion provides general information that may be useful when determining if a Loan Estimate and Closing Disclosure are required, including information related to each of the major questions set forth in the flowchart.

As you would expect

BSA Bootcamp To Go On Sale Late May

Adam Witmer

If you or someone else on your team is looking for a foundational class on the essential element’s of a financial institution’s BSA/AML program, then you might be happy to know that our BSA Bootcamp will be going on sale later this month (late May).  Designed for those looking for a fundamental BSA/AML training program (like new BSA Officers, BSA back-ups, auditors, or anyone else wanting to increase their understanding of the core BSA rules), this course covers all of the key areas a BSA professional should know including:

  • A history and overview of the Bank Secrecy Act and anti-money laundering rules

  • An explanation of BSA risk and the risk assessment process

  • The five pillars of BSA

  • Key elements of a BSA/AML program (CIP, CDD, CTRs, SARs, MILs, OFAC, ect.)

  • Tips for managing a BSA program

While this program isn’t yet on sale at this time, we wanted to give our members a heads up that the program will go on sale later this month, so you can start planning now. The full curriculum (and an overview video) can be found in our store at: https://www.compliancecohort.com/video-webinar-bsa-bootcamp.

CFPB Requests Information on Remittance Rule

Adam Witmer
Regulatory Update

On April 25, 2019, the CFPB issued a “Request for Information” (RFI) on its remittance rule.

Implemented a few years ago, the Remittance Rule has fairly strict requirements for companies which send international money transfers - known as “remittance transfers” - on behalf of consumers. Among its requirements, the Rule mandates that providers generally must disclose the exact exchange rate, the amount of certain fees, and the amount expected to be delivered to the recipient.     

Managing Reg D Excessive Transactions

Adam Witmer
Regulation D

Regulation D is an interesting regulation for compliance professionals as it isn’t a consumer protection rule, but rather was created by the Federal Reserve to help set monetary policy.  That said, compliance professionals typically focus on just a few elements of Regulation D such as ineligible entities on NOW accounts, waiving early withdrawal penalties, and, of course, monitoring for excessive transactions on savings accounts.

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