NMLS Registration to Open Next Week

Adam Witmer
SAFE Act

As is the case each year, the annual registration period for NMLS registration begins on November 1, 2019. This year, the NMLS registry has explained that the Registry will be down for site maintenance for parts of the day October 31, 2019, in preparation for the registration period that begins on the next day. Just in case any of our members were planning to come in early to get a head start on the registration process, keep in mind that the site will not open until 7:00 am ET, on Friday, November 1, 2019.

Giveaway! Enter for a chance to win our 3Q 2019 Quarterly Compliance Update.

Adam Witmer

As we are getting ready to roll out the 3rd Quarter of our Quarterly Compliance Update program, we thought that we would give our members a chance to win a free enrollment to this course. To enter, send a simple “enter me” (or something similar, more detailed, or funnier…) to members@compliancecohort.com by 10/22/19 for a chance to win our 3Q 2019 program. You can view the (still tentative) curriculum at https://www.compliancecohort.com/video-webinar-3q2019-quarterly-compliance-update.

Annual Director Training Requirements

Annual Director Training Requirements

Adam Witmer
Compliance Management

Adam uses this Compliance Clip (video) to review the annual compliance training requirements for directors - or lack thereof. That said, there are a few expectations regulators have had for director training, and Adam explains some of these topics and reminds viewers of a few annual reports that do need to go to the board.

Thank You!

Adam Witmer

We would like to thank all of you who continue to refer us to other compliance professionals as we continue to see new members every single day. Without our members, we wouldn’t be able to continue this service, so thank you to all who collaborate with us by referring new members to the Compliance Cohort!

Quarterly Compliance Update to be Available Soon!

Adam Witmer

Our upcoming 3Q 2019 Quarterly Compliance Update will be available within the next few weeks. The manual is almost complete for this program, so we will be going into the studio to record the video for this program. If you haven’t seen the curriculum for this program, it really is amazing how much compliance activity took place during the last quarter.

For example, one of the big changes we saw was an update to the appraisal threshold for residential real estate transactions. While this topic sometimes sits on the fringes of compliance responsibilities, we have decided to tackle this topic as many of you are responsible for dealing with this change. Therefore, we are featuring appraisal thresholds in our 3Q 2019 Quarterly Compliance Update. We will also be offering a stand-alone training program just for the new appraisal final rule.

You can view the full curriculum of our 3Q 2019 program at https://www.compliancecohort.com/video-webinar-3q2019-quarterly-compliance-update.

Which Appraisal Threshold for Two 1-4 Family Properties?

Which Appraisal Threshold for Two 1-4 Family Properties?

Adam Witmer
Appraisals

In this Compliance Clip (video), Adam answers a question related to which appraisal threshold applies for a consumer-purpose loan secured by two 1-4 family properties (for a bank). As the answer to this might not be what you expect it to be, Adam points out a few of the challenges of the new appraisal thresholds. This video provides a great overview of when the different appraisal thresholds apply to bank loans.

CFPB Issues HMDA Final Rule to Implement Partial Exemption

Adam Witmer
HMDA

On October 10, 2019 the Consumer Financial Protection Bureau (CFPB) issued a rule which finalizes some parts of its May 2019 Notice of Proposed Rulemaking that we previously reported on. This new final rule extends for two years the current temporary threshold for collecting and reporting data about open-end lines of credit under HMDA. The rule also clarifies partial exemptions from certain HMDA requirements which Congress added in the Economic Growth, Regulatory Relief, and Consumer Protection Act (EGRRCPA).

New Appraisal Threshold Now Effective

Adam Witmer
Regulatory Update

As we reported last week, the regulators issued joint guidance to increase the threshold for residential real estate transactions requiring an appraisal from $250,000 to $400,000.  The appraisal threshold adjustment was effective the day after publication in the Federal Register.  Since the final rule was published on 10/8/19, the new $400,000 threshold is now in effect and can be utilized by banks on applicable loans.

For those looking for a comprehensive break-down of the new appraisal threshold rules, we will be offering training on this topic as both part of our 3Q 2019 Quarterly Compliance Update as well as a stand-alone product. Those programs will both be available in our store at www.compliancecohort.com/store over the next few weeks.

FinCEN Updates CTR FAQ 16 - Again...

Adam Witmer
BSA, Regulatory Update

Over the last week, FinCEN updated their CTR Frequently Asked Question (FAQ) # 16 - for the third time in recent days. A few weeks ago, FinCEN started the process of changing how they want CTR filers to complete CTRs when a person has multiple “roles” in the transaction. Initially, FinCEN updated CTR FAQ 16 with a new answer, but then reverted to the original answer to FAQ 16 after apparent multiple calls from bankers questioning this change (that did not have an associated announcement or even changes to the CTR instructions). This week, we have received reports that FinCEN released a statement

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