Jul 24

Jul 24 5 Reasons Why the New Reg CC Amendments are Terrible!

In this Compliance Clip (video), Adam explains 5 reasons why the new Regulation CC amendments are terrible for financial institutions. Okay, they aren’t really “terrible,” but they definitely aren’t ideal or as good as they could have been. As you will see in this video, there are a number of challenges this new rule creates, so it will be imperative for financial institutions to quickly create a strategy for implementing these rules. Adam concludes by providing a brief overview of a solution to help you easily navigate the challenges associated with this new rule - our new training program on the Regulation CC amendments, which can be found at https://www.compliancecohort.com/video-webinar-regulation-cc-june-2019-amendments

Jul 23
Jul 23 Agencies Issue Statement Risk-Focused BSA/AML Supervision

Adam Witmer

BSA, Regulatory Update

On July 22, 2019, the joint agencies issued a statement to improve transparency of risk-focused BSA/AML supervision. The statement outlines common practices for assessing a bank's money laundering/terrorist financing risk profile, assisting examiners in scoping and planning the examination and initially evaluating the adequacy of the BSA/AML compliance program. Using this approach, the agencies generally are able to allocate more resources to higher-risk areas and fewer resources to lower-risk areas when conducting BSA/AML examinations. The statement does not establish new requirements, and also notes that having a risk-based compliance program enables a bank to allocate compliance resources commensurate with its risk.

Jul 22
Jul 22 NCUA Increases CRE Threshold to $1M

Adam Witmer

Regulatory Update

On July 18, 2019, the NCUA released a rule that amends their policy requiring appraisals for certain transactions, including increasing the threshold below which appraisals are not required for commercial real estate transactions from $250,000 to $1,000,000. In addition to this, the rule does three other things: (1) it restructurs the rule to enhance clarity; (2) it exempts from the rule certain federally related transactions involving real estate in a rural area; and (3) is makes conforming amendments to the definitions section. The rule is not yet final, but will be so 90 days after publication in the federal register.

Jul 21
Jul 21 New Class Coming Soon: UDAAP Foundations

Adam Witmer

We are getting ready to go into the studio for a new Compliance Class called UDAAP Foundations. As you would expect, this program is going to address everything you need to know related to Unfair, Deceptive, or Abusive Acts or Practices (UDAAP). This program will be divided into two parts: 1) An overview of UDAAP rules and 2) Examples of UDAAP violations. Be sure to look for our initial release (in August) as we will have an “early bird” discount at that time.

A preview of this upcoming Compliance Class can be found here: https://www.compliancecohort.com/udaap-foundations

Jul 18
Jul 18 Regulation CC Training Coming Soon!

Adam Witmer

We are getting ready to hit the studio to record our upcoming training on the new Regulation CC amendments that were released in June of 2019. If you aren’t yet aware of these change, you are going to want to pay attention as these changes are going to have a significant impact on your organizations in a couple of ways.

But don’t worry, we will be providing a short and sweet need-to-know training to get you caught up with these rules as quick and easy as possible. And they will be available to purchase soon.

You can learn more about our upcoming training on the June 2019 Regulation CC Amendments at https://www.compliancecohort.com/video-webinar-regulation-cc-june-2019-amendments

Jul 18

Jul 18 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.

Jul 18
Jul 18 CFPB Issues Advisory on Elder Financial Exploitation

Adam Witmer

BSA, Regulatory Update

On July 17, 2019, the CFPB issued an updated advisory to financial institutions encouraging them to work with law enforcement agencies “whenever they suspect that an older adult is the target or victim of financial exploitation.” In their advisory, the CFPB also recommended that financial institutions file SARs - which FinCEN has already provided guidance on.

Jul 15
Jul 15 FinCEN Updates List of Deficient Countries (7/12/19)

Adam Witmer

BSA

On July 12, 2019, FinCEN released an advisory on the FATF-identified jurisdictions with AML/CFT deficiencies. This advisory, known as FIN-2019-A004, relays information to US financial institutions regarding countries the Financial Action Task Force (FATF) has identified as having deficiencies.

Jul 14
Jul 14 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!

Jul 12
Jul 12 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.