CFPB Reopens Second HMDA Comment Period

Adam Witmer
HMDA, Regulatory Update

As we reported last month, the CFPB decided this summer to reopen two comment periods relating to the Home Mortgage Disclosure Act (HMDA). On July 31, 2019, the CFPB announced the reopening of the comment period for specific aspects of the proposed rule published by the Bureau in the Federal Register on May 13, 2019 (84 FR 20972) (May 2019 Proposal). In their announcement, the Bureau explained that one of the main reasons for reopening the original 30-day comment period is to allow commenters to be able to

CFPB Issues ANPR on QM Fix

Adam Witmer
Regulation Z, Regulatory Update

On July 25, 2019, the CFPB announced an Advance Notice of Proposed Rulemaking (ANPR) seeking information relating to the expiration of the temporary qualified mortgage (QM) provision applicable to certain mortgage loans eligible for purchase or guarantee by the Government Sponsored Enterprises (GSE - i.e. Fannie Mae & Freddie Mac). This provision, also known as the GSE patch, is scheduled to expire no later than Jan. 10, 2021.

As the ANPR states that the Bureau currently plans to allow the GSE Patch to expire around January 2021, financial institutions…

Thank You!

Adam Witmer

We continue to get reports that our members are referring the Compliance Cohort to other compliance professionals. Therefore, we wanted to say thank you to all of you who have referred us to others as word-of-mouth referrals are always appreciated and we are grateful for any and every referral.

Keeping up with regulatory changes?

Adam Witmer
Regulatory Update

At the Compliance Cohort, we understand that keeping up with regulatory changes is one of the most challenging aspects for you as a compliance professional. On one hand, you have hundreds of daily tasks that must get done and you really don’t even have time to do them all. On the other hand, changing rules are somewhat difficult to keep up on and can take considerable amounts of time to both comprehend and then understand how a rule applies to your specific organization.

To assist you and your financial institution with “regulatory change management,” we have created our Quarterly Compliance Update program. The way this program works is that each quarter, we release a new training class that covers all of the regulatory activity from the prior quarter of the year. For example, our 2Q 2019 Quarterly Compliance Update covers all of the regulatory changes that took place during the months of April, May, and June - and boy was there quite a bit of activity. (The full curriculum for the program can be viewed at the link below.)

Using our “virtual classroom approach,” we deliver each Quarterly Compliance Update class with you in mind, answering these two questions: what has happened and what do you need to know? Our goal is to save you considerable amounts of time sifting through regulatory updates and provide you with the need-to-know information so that you can take quick and efficient action. We want to make your job easier, and we try to focus everything in this program around this focus. We’ve been told that our program not only helps you understand new rules, but also helps you understand what needs to be done - helping you to form a game-plan to tackle regulatory change.

If you think that our Quarterly Compliance Update might be beneficial for you, be sure to check out our new 2Q 2019 class as it available at a pretty nice discounted price now through Thursday August 1, 2019.

https://www.compliancecohort.com/video-webinar-2q2019-quarterly-compliance-update

5 Reasons Why the New Reg CC Amendments are Terrible!

5 Reasons Why the New Reg CC Amendments are Terrible!

Adam Witmer
Regulation CC

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

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.

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.

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

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

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