Hosting a Halloween Costume Contest

In this potentially embarrassing Halloween special Compliance Clip (video), Adam answers this week’s question dressed as none other than…. well, you will have to watch the video to see. (Yes, Adam is in a costume in this video and if you don’t recognize the character, stick around to the end of the video for an explanation of who it is!) You don’t want to miss this one-of-a-kind video!

On 10/29/19, the USDA released a long-awaited interim final rule relating to the growing of industrial hemp. This program, as required by the 2018 Farm Bill, will establish a consistent regulatory framework around hemp production throughout the United States. As explained in their release, the USDA rule includes provisions for…

As we are planning our course for 2020, we are looking for feedback from our members to make sure we are the best resource we can be. If you would be interested in providing feedback (through methods yet to be determined), send an email to members@compliancecohort.com with a title that says something like “I’d love to be a strategist for the Compliance Cohort.”

As announced earlier this week, we have discounted two of our training programs through 10/31/19: 1) our 3Q 2019 Quarterly Compliance Update and 2) our program on the Regulation CC June 2019 Amendments.

The 3Q 2019 Quarterly Compliance Update covers all of the regulatory changes that took place in July, August, and September of 2019 and includes topics like the new TRID FAQs, the appraisal thresholds, a few CTR reporting changes that you may have missed, and a whole lot more. This program runs over two hours and the full curriculum can be found at www.compliancecohort.com/video-webinar-3q2019-quarterly-compliance-update.

Our training program on the Regulation CC June 2019 Amendments takes a deep-dive into the amendments to Regulation CC that must be complied with by July 1, 2020 (and will have a big impact on check holds).  This program condenses the new rules down to the need-to-know parts and runs just 53 minutes.  You can find more information about the Regulation CC June 2019 Amendments class at: https://www.compliancecohort.com/video-webinar-regulation-cc-june-2019-amendments.

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.

LE Requirements for Online Applications Not Submitted

Adam uses this Compliance Clip (video) to discuss what to do in situations where applications containing the six pieces of information (constituting an application under TRID) are located on an online application system, but the borrower never hits the “submit” button, so a Loan Estimate doesn’t go out to the applicant within 3 days of collecting this information (if ever). In other words, Adam answers the question of whether collecting the six pieces of information in an online application where the borrower doesn’t submit the application constitutes a received application under TRID, requiring an LE?

On October 24, 2019, the CFPB announced its third symposium in a series that started earlier in 2019. The most recent discussion will focus on Section 1071 of the Dodd Frank Act, which amends the Equal Credit Opportunity Act (ECOA) to require financial institutions to collect, report, and make public certain information concerning credit applications made by women-owned, minority-owned, and small businesses.

As has been the case with the other two symposiums, this program will