On June 25, 2019, the CFPB held a symposium on abusive acts or practices. This symposium was the first in a series aimed at stimulating a proactive and transparent dialogue to assist the Bureau in its policy development process, including possible future rulemakings. The CFPB has explained that the format of each symposium will include a discussion panel of experts with a variety of viewpoints on the topic. The recent abusive acts or practices symposium included two panels of UDAAP experts and also included

On June 12, 2019, the Federal Housing Finance Agency (FHFA), Fannie Mae, and Freddie Mac announced that the optional use period for the redesigned Uniform Residential Loan Application (URLA) form has been delayed again.  It was planned that the redesigned URLA could be used starting on July 1, 2019 with required use by January 1, 2020. This announcement delays the optional use period for the new URLA, meaning that lenders should not yet begin using this form. 

As the new rules for the mandatory purchase of private flood insurance go into effect on Monday, July 1, 2019, we are offering one final sale on our training program on these new rules. This program is discounted at $30 off the regular price through the end of Today, June 28, 2019.  This short (45 minute) Compliance Class is an efficient way to get up-to-speed on the new interagency rules for Private Flood Insurance that must be followed, starting on Monday, July 1, 2019.   While the final rule is fairly short in length, there are some complexities that applicable financial institutions should be aware of. For example, if the “compliance aid” is not present, financial institutions must conduct a review of  each private flood insurance policy to determine if it meets the definition of “private flood insurance,” and if it does, the policy must be accepted. As compliance with the rule is required by 7/1/19, this is your last chance to take action (if you haven’t done so already) to be prepared for the upcoming implementation date.  

The course curriculum for our Private Flood Insurance class can be found at https://www.compliancecohort.com/video-webinar-private-flood-insurance-2019-final-rule

CFPB Releases Regulation CC Amendments (Video)

In this Compliance Clip (video) Adam provides an overview of the Regulation CC amendments that were released on June 24, 2019. While these amendments are really just a small part of what is yet to come (probably very soon), these amendments will cause a number of challenges for financial institutions. First of all, the $200 and $5,000 thresholds have been increased for inflation - and will continue to be increased for inflation on a regular basis. Secondly, each time the threshold is increased, a change of terms notice is going to need to be delivered to applicable customers. Finally, there are a few other minor changes in this new final rule, which Adam explains in this video.

4 Tips for Conducting BSA Training for Directors

In this Compliance Clip (video), Adam provides four tips that can be used when conducting BSA/AML training for directors of the Board. These tips are designed to help BSA/AML professionals craft a short, sweet, and sufficient training program for the board of directors.

For those interested in more information on providing Bank Secrecy Act training to the board of directors, be sure to check out our own BSA/AML Training for Directors in our at https://www.compliancecohort.com/bsa-training-for-directors.

On June 13, 2019, the FDIC released a new publication called Consumer Compliance Supervisory Highlights.  This publication includes a high-level overview of consumer compliance issues identified during 2018 by the FDIC during their supervision of state non-member banks and thrifts.  As stated in their release (FIL-31-2019), the purpose of this publication is to increase transparency with the FDIC’s supervision activities.

As is the case each quarter, we will be releasing our 2Q 2019 Quarterly Compliance Update once the quarter ends - probably by the end of July. This program, released four times a year, provides an overview of the main consumer compliance activity that took place during the prior quarter of the year. Designed for compliance officers and those responsible for overseeing and managing the compliance function, this program assists with regulatory change management by covering the need-to-know regulatory changes and activity that take place throughout the year. Each Quarterly Compliance Update program comes with a video of the instructor in front of presentation slides as well as a comprehensive manual where attendees can take notes and keep this document as a reference tool.

The full agenda to our 2Q 2019 Quarterly Compliance Update will be available within the next few weeks.

While the 2Q 2019 Quarterly Compliance Update is not yet available, prior Quarterly Compliance Updates can be viewed in our store at www.compliancecohort.com/store

Promptly Investigating Under Regulation E

In this Compliance Clip (video), Adam breaks down the requirement to investigate “errors” promptly under Regulation E. This video gives an overview of the rule and provides a great case study of “what not to do” regarding delaying investigations - and how doing so can have major consequences, such as UDAAP violations. If you are delaying investigations of Reg E claims for any reason, Adam will show you how this might be a major problem for you.