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.
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In this Compliance Clip (video), Adam answers a question regarding whether Member FDIC must be included in a Radio ad. As you will see, the answer to this is quite complex and Adam breaks the answer down in simple, easy-to-understand, layman’s terms. This video clip includes a transcript.
On June 28, 2019, the CFPB released their annual report on fair lending. Coming just seven months after the last annual report to congress (12/4/18), this annual report to Congress describes the Bureau’s fair lending activities in innovation, outreach, prioritization, guidance and rulemaking, supervision, and enforcement for calendar year 2018. This is the first report released under new CFPB Director, Kathleen Kraninger.
NOTE: The 2018 CFPB fair lending report to Congress will be included in our 2Q 2019 Regulatory Update program, which will be released in July of 2019, covering all of the regulatory changes that a compliance professional needs to be aware of from the activity that occurred during the 2nd Q of 2019.
As we work to build careers in regulatory compliance, we often look for opportunities to become more valuable to our organizations and to establish ourselves as experts. While experience and self-learned technical expertise is a must for any compliance professional, finding a way to be recognized as an industry leader can help to establish credibility with both examiners and peers. One way to do this is to obtain a professional regulatory compliance certification. This article explores 3 options for obtaining a regulatory compliance certification.
On 7/2/19, the FDIC announced updates to their Consumer Compliance Examination Manual (CEM) which examiners utilize when conducting compliance examinations. The manual contains exam procedures for consumer compliance regulations, the Community Reinvestment Act rules, and other supervisory requirements and helps to provide consistency among examiners when conducting examinations.
One of the areas of greatest concern for financial institutions continues to relate to Unfair, Deceptive, or Abusive Acts or Practices (UDAAP). While UDAAP violations have been on the forefront of the minds of most compliance officers since the Dodd-Frank Act added “abusive” into the mix, this area still causes challenges for financial institutions as regulators continue to cite financial institutions for UDAAP violations for practices that had not previously been identified as unfair, deceptive, or abusive. This article explores a number of UDAAP violation examples.
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 28, 2019, the CFPB updated their small entity compliance guide which summarizes the Payday Lending Rule’s payment-related requirements. On their website, the CFPB explains that the guide was updated to incorporate the changes that the Delay Final Rule made to the 2017 Payday Lending Rule.
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.
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.
