Our newest program, BSA Basics, is now on sale. This program is designed as a high-level overview of the requirements of a financial institution’s BSA/AML program. Taking just over an hour to complete, BSA Basics is a quick way to get general BSA/AML training - which is actually something the regulators look for during an examination. Our instructor (Adam Witmer), provides an overview of BSA/AML rules and then dives into a good example of how money laundering can work and what financial institutions should be looking for with their programs. You can learn more about BSA Basics in our store at www.compliancecohort.com/bsa-basics.

HMDA Temporary Financing for Bridge Loans

In this Compliance Clip (video), Adam talks about HMDA applicability for bridge loans under the new temporary financing rules. While these rules have been around for a bit now, we are still seeing some confusion with reporting (or not) bridge loans as it relates to HMDA.

On August 30, 2019, the Federal Financial Institutions Examination Council (FFIEC) announced the availability of HMDA data for 5,683 U.S. financial institutions. This data comes from HMDA reporters including banks, savings associations, credit unions, and mortgage companies. The release includes

This is a guest post by one of our Cohort members, Theresa Zuber.  Theresa is the VP/Compliance Officer at a $450 million community bank and shares her years of experience in banking by providing us with an example of things to consider in building and designing a compliance management system. ——

Between policy reviews, risk analysis, board reporting, annual training, complaint tracking and documentation for examiners, it can be difficult to keep track of all the individual tasks and responsibilities found within a Compliance Management System (CMS).  In fact, keeping a CMS going can sometimes feel more like a juggling act than banking. Therefore, we have the following Compliance Management System example to give you the framework you need to take control of your Compliance duties and ensure nothing slips through the cracks.  

On August 21, 2019, the Financial Crimes Enforcement Network (FinCEN) issued an advisory (FIN-2019-A006) to alert financial institutions to possible schemes related to the trafficking of fentanyl and other synthetic opioids.  FinCEN explains that this new advisory will assist financial institutions in detecting and reporting suspicious activity, ultimately making it harder and more costly for criminals to (i) commit crimes related to the trafficking of synthetic opioids; (ii) hide and use their illicit money; and (iii) continue fueling the opioid epidemic that is currently occurring in the United States. 

Fin-2019-A006 highlights the

On 8/19/19, the NCUA issued guidance for federally insured credit unions on how they can serve lawfully operating hemp businesses.  As the 2018 Farm Bill made a number of changes to how hemp is treated under federal law, some credit unions have lawfully operating hemp businesses within their fields of membership.  The NCUA explains that credit unions may provide the customary range of financial services for business accounts, including loans, to lawfully operating hemp related businesses within their fields of membership.

In the guidance, the NCUA explains that

As we explained before, Fannie Mae & Freddie Mac (the GSEs) announced in June 2019 that the optional use period for the new version of the Uniform Residential Loan Application (URLA) and automated underwriting system (AUS) implementations would be postponed. In a more recent release, the GSEs explained that they have now been directed to make specific modifications to the redesigned URLA, which is going to delay the February 1, 2020 implementation date. The following changes will be made to the redesigned URLA: