NEW CLASS: UDAAP Foundations to be available soon!

Adam Witmer

Our newest Compliance Class, UDAAP Foundations, will be released within the next week or so. We have finished recording the videos (nearly 3 hours!) and are now in the process of editing, uploading, and dealing with all the back-end work that goes into creating a video course. ;-). This course is a comprehensive overview of UDAAP rules and does something we believe is essential to mitigate UDAAP risk in your organization - we review over 50 known UDAAP violations. Yep, we believe that one of the best ways to mitigate UDAAP risk is to compare known UDAAP violations with the practices at your organization, so we have designed this course to provide you with a checklist to do just that. Part II of our program spends over an hour and a half discussing over 50 known UDAAP violations that have been identified by the regulators at other financial institutions. And just like all of our programs, UDAAP Foundations will have an Early Bird discount when we launch it within the next week or so. To have a sneak preview of what will be included in this course, take a look here: www.compliancecohort.com/udaap-foundations

CFPB Updates TRID FAQs Again

Adam Witmer
Regulation Z, TRID, Regulatory Update

The CFPB has again updated the TRID FAQs on their website. This update incorporates five new questions and answers relating to providing loan estimates to consumers. As has been the case with the previously released FAQs, these five new questions don’t really tell us anything we didn’t already know. That said, we will be including a review of these FAQs in our 3Q 2019 Quarterly Compliance Update program (planned to be released sometime in October 2019.

UDAAP Foundations Coming Soon!

Adam Witmer

The next Compliance Class we will be launching will be 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. The first part of our program will provide an overview of UDAAP rules and how we got to where we are today. It will include a review of the FTC’s three-prong tests and outline what you need-to-know regarding UDAAP regulations. Following this, the second part of our program will spend a good amount of time reviewing a number of UDAAP violations that have been cited over the years. Our experience tells us that one of the best ways to prevent UDAAP violations in your organization is to know what other organizations have been cited for, and then ensure you aren’t utilizing those inappropriate practices. This part of the program will explain each cited violation covered so that you can go back to your organization and ensure that you are not utilizing the same practice that another financial institution was penalized for.

We plan to release this program in mid to late August (so be sure to watch for our “early bird” discount at that time). A preview of this upcoming Compliance Class can be found here: https://www.compliancecohort.com/udaap-foundations

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

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