HMDA Income for Cosigners (Video)

HMDA Income for Cosigners (Video)

Adam Witmer
HMDA

In this Compliance Clip (video), Adam explains how to report income under the Home Mortgage Disclosure Act in relationship to cosigners. The question we have this:

Question: A loan has one borrower and a co-signer. Do I report the income of just the borrower, or do I report the income of the co-signer since we wouldn’t do the loan with just the borrower?

The answer to this come from 1003.4(a)(10) of Regulation C. In this video, Adam breaks down the different HMDA requirements for reporting income as it relates to co-signers and breaks down a few key phrases as well as the applicable commentary to Regulation C.

Thank You!

Adam Witmer

We would like to thank all of you who continue to refer us to other compliance professionals as we continue to see new members every single day. Without our members, we wouldn’t be able to continue this service, so thank you to all who collaborate with us by referring new members to the Compliance Cohort!

Two Training Classes Coming Later This Month!

Adam Witmer

Later this month, we will be releasing two new Compliance Classes (video training webinars):

The first course we will have available is the second installment of our Quarterly Compliance Update Program. As is the case each quarter, this program will cover all of the need-to-know changes that took place in the last quarter - in this case, April, May & June of 2019. This program is a great way to keep up on the compliance changes every compliance professional should be aware of. While not available yet, the planned curriculum for our 2Q2019 Quarterly Compliance Update can be found at: https://www.compliancecohort.com/video-webinar-2q2019-quarterly-compliance-update

The second new course that will be available later this month is our program on the Regulation CC June 2019 Amendments. If you haven’t caught wind of these changes to check holds, you are going to want to take a look at them sooner than later as they are going to cause some pretty significant challenges for those managing Regulation CC. In short, the hold thresholds of $200 and $5,000 (among other amounts) are being increased every 5 years for inflation. While not yet available, an overview of what will be covered in this course can be found at: https://www.compliancecohort.com/video-webinar-regulation-cc-june-2019-amendments

Note: Each of these programs will have an “early bird” discount available to members, so be sure to watch for this course in the coming months. To be placed on our waiting list, reply to this email letting us know which course you are interested in.

CFPB Releases Annual Fair Lending Report for 2018

Adam Witmer
Regulatory Update, Fair Lending, Regulation B

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.

3 Great Bank Compliance Officer Certifications

Adam Witmer
Compliance Management

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.

FDIC Updates Exam Manual

Adam Witmer
Regulatory Update

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.

UDAAP Violation Examples

Adam Witmer
UDAAP

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.

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