What is the 30-Day ECOA Rule?

Adam Witmer
Adverse Action, Regulation B

GUEST POST! This is another feature article by one of our Compliance Cohort members, Jennifer Johnson.  Jennifer is a Vice President and Chief Risk Officer at a $225 million community bank, and shares her years of experience in multiple banks with us in this fantastic article on the 30-day Reg B rule.

In an ideal world, loan applicants would come to us fully prepared with all the documentation we need to make a loan decision. I don’t know about you, but I certainly do not live in that ideal world. More commonly, applicants come to us with a loan request and bits and pieces of what we need, which can lead us to stash applications on the shelf while we wait for more information. Time passes, and before you know it, we have violated Regulation B’s 30-day rule. “Wait!” you may say, “what are you talking about? I didn’t have a completed application! How could I have violated ECOA’s 30-day rule?”  While it may be true that you didn’t have a completed application, if you stop there, you’re missing some of the important nuances of Regulation B’s notification requirements…

NCUA Speech Says NCUA Needs Greater Compliance Enforcement

Adam Witmer
Regulatory Update

In a speech prepared for delivery on September 10, 2019, NCUA Board Member Todd Harper gave a speech at the Women in Housing and Finance Policy Lunch. Of interesting note for compliance professionals - especially those in credit unions regulated by the NCUA - is that Mr. Harper explained that he believes there is a need for improved consumer protection examinations and enforcement. Specifically, Mr. Harper explained that…

What is BSA?

What is BSA?

Adam Witmer
BSA

Adam uses this Compliance Clip (video) to explain what BSA is in the banking industry. This video provides a high-level overview of BSA and money laundering, giving a general overview of the rule. For more information on BSA and anti-money laundering laws, take a look at our BSA Basics program at www.compliancecohort.com/bsa-basics.

FinCEN Launches New Division

Adam Witmer
BSA, Regulatory Update

The Financial Crimes Enforcement Network (FinCEN) recently (8/28/19) launched a new Global Investigations Division (GID), which will be responsible for implementing targeted investigation strategies rooted in FinCEN’s unique authorities under the Bank Secrecy Act (BSA) to combat illicit finance threats and related crimes, both domestically and internationally. According to the FinCEN release, GID will leverage FinCEN’s BSA authorities, including Section 311 of the USA PATRIOT Act, to investigate and target terrorist finance and money laundering threats, and GID will work more closely with foreign counterparts to coordinate actions against such threats when appropriate. FinCEN also states that GID will

Flood Exam Manual Updated for Private Flood Insurance Rules

Adam Witmer
Regulatory Update, Flood

The Federal Financial Institutions Examination Council recently (8/22/19) updated their Flood Exam manual to reflect the new requirements for mandatory acceptance of private flood insurance. Mandatory acceptance of private flood insurance was mandatory in July of 2019. If your organization is looking for more information on this now required rule, be sure to take a look at our premium course on private flood insurance at https://www.compliancecohort.com/video-webinar-private-flood-insurance-2019-final-rule. Read more on this article to get a link to the updated exam procedures.

BSA Basics Now on Sale!

Adam Witmer

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

HMDA Temporary Financing for Bridge Loans

Adam Witmer
HMDA

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.

FFIEC Announces 2018 HMDA Data

Adam Witmer
Regulatory Update

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

A Compliance Management System Example

Adam Witmer
Compliance Management

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.  

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