CFPB Summer 2019 Edition of Supervisory Highlights

Adam Witmer
Regulatory Update, Compliance Management

The CFPB has released the summer 2019 Edition of Supervisory Highlights. In this issue, topics include UDAAPs, auto loans, Supervision, compliance, credit cards, credit reports and scores, debt collection, Fair Credit Reporting Act, mortgage origination. The full version of Supervisory Highlights can be found here.

As you might expect, we will be coving the portions of Supervisory Highlights that relate to compliance professionals in our next Quarterly Compliance Update. You can view the tentative curriculum for our Q3 2019 Quarterly Compliance Update here.

New Edition of Consumer Compliance Outlook Released

Adam Witmer
Regulatory Update

On 9/20/2019, the Federal Reserve released the Second Issue 2019 of their Consumer Compliance Outlook. This edition includes two feature articles on Promoting Effective Change Management and Vendor Management Considerations for Flood Insurance Requirements. The current version of Consumer Compliance Outlook can be found here and we will be including this topic in our Q32019 Quarterly Compliance Update.

BSA ALERT! Update to CTR FAQ 16?

BSA ALERT! Update to CTR FAQ 16?

Adam Witmer
BSA, Regulatory Update

In this Compliance Clip (video) Adam talks about a whirlwind in the BSA world that took place over the last few weeks. FinCEN apparently made an update to CTR FAQ 16 (without any notification or clarification) that would change how CTRs are reported when a person conducting a transaction has multiple “roles,” such as would be the case if an individual made deposits on both their personal account and the account for a business. Adam explains what happened with FAQ 16 and what we need to look for going forward. For those who enjoy a bit of excitement in the BSA world, the change to FAQ 16 has definitely given something to think about (and to share with your BSA officer if they aren’t aware of this). Click this link to watch the video.

HMDA Changes Coming & Comments Due

Adam Witmer
HMDA, Regulatory Update

We received a question this week about when to expect more HMDA changes.  That’s right, more HMDA changes are on the horizon, but we really don’t know when to expect them.  As we reported back in May of 2019, the CFPB has issued two things that could result in more HMDA changes: 1) a Notice of Proposed Rulemaking as well as 2) an Advance Notice of Proposed Rulemaking. This article provides a summary of the possible changes, what to look for, and a reminder that comments on both potential changes are due on October 15, 2019.

Flood Program Set to Expire September 30 - What to do?

Adam Witmer
Regulatory Update, Flood

As the twelth exetension of the National Flood Insurance Program is set to expire on September 30, 2019, financial institutions must again hold their breath (no pun intended) to see if Congress yet again kicks the can down the road by renewing the program one more time. While we at the Compliance Cohort will be sure to keep you up-to-date with any changes to the Flood program, you may be wondering what you should do if the Flood program does, in fact, expire. Check out this article for guidance on what your financial institution should do if the flood program were to expire: https://www.compliancecohort.com/blog/what-to-do-if-the-nfip-expires

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.

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