Agencies Issue Hemp Guidance

Adam Witmer
BSA, Regulatory Update

On 12/3/2019, four regulators (FDIC, Federal Reserve, OCC, and FinCEN) issued a joint statement to clarify requirements for providing financial services to hemp-related businesses. The statement, which runs only three pages long and has about as many footnotes as it does content, emphasizes that banks are no longer required to file SARs for customers solely because they are engaged in the growth or cultivation of hemp in accordance with applicable laws and regulations.  Similar to recent NCUA hemp guidance, it is important to note that this guidance seems to…

Cyber-Week SALE Starting Next Week!

Adam Witmer

As the month is winding down and the holidays are just around the corner, we will be having a cyber-week sale in our store. Not that anyone really wants a compliance training video for Christmas (really, coal might be better), but everyone does like a discount on compliance training. Therefore, everything in our store will be on sale starting on Wednesday, 11/27/19. If you have been putting off your compliance training until the end of the year (or looking to get a head start on 2020 training), this may be a great option for you. Be sure to watch for more information over the next week, but you can view the training programs in our store by going to www.compliancecohort.com/store.

Using the Repeated Overdrafts Hold Reason

Using the Repeated Overdrafts Hold Reason

Adam Witmer
Regulation CC

In this Compliance Clip (video), Adam discuses the two different options for using the “repeated overdrafts” hold reason and also discusses how the new inflation adjustments will change this reason.

For those interested in learning more about how the June 2019 Reg CC amendments will impact the funds availability rules, be sure to check out our Reg CC Training for Tellers in our store at www.compliancecohort.com/reg-cc-training-for-tellers.

NFIP Extended for Fourteenth Time

Adam Witmer
Flood, Regulatory Update

On 11/19/19, the House Committee on Appropriations released a statement that the House passed a continuing resolution to extend federal government funding through December 20, 2019, which includes an extension of the National Flood Insurance Program (NFIP). This is the fourteenth temporary extension since 2017 while lawmakers work on a longer-term solution that would

UPDATE on HMDA Changes! - CFPB Gives Timetable for Final Rules

Adam Witmer
HMDA, Regulatory Update

As the new year is quickly approaching, we have continued to receive a number of questions regarding a potential final HMDA rule that would (possibly) increase the thresholds for reporting of both closed-end and open-end loans.  This, of course, could provide significant relief to HMDA reporters, especially those reporters who have fairly small HMDA LARs.

As the CFPM released their Fall regulatory agenda this week (11/20/19), the Bureau provided us with a bit of insight into their plans for two potential new HMDA rules that could provide significant relief…

CFPB Releases 2019 Fall Agenda

Adam Witmer
Regulatory Update

On 11/20/19, the CFPB released their twice-a-year agenda of planned rulemaking activities.  Interesting observations of changes from the spring agenda include the addition of “E-Sign Act Requirements” being added to the long-term actions list while “Regulation E Modernization” was removed from the long-term actions list.  It should also be noted that, while this list outlines their planned agenda, that things can change.  For example…

CFPB Assessment of TRID

Adam Witmer
Regulatory Update, TRID

On 11/20/19, the CFPB announced a request for public comment on an assessment it will conduct on the TRID rules. 

As part of its assessment, the Bureau intends to address TRID’s effectiveness in meeting the purposes and objectives of the Dodd-Frank Act, the specific goals of the rule, and other relevant factors.  The public is invited to comment on the feasibility and effectiveness of the assessment plan, recommendations to improve the assessment plan, and recommendations for modifying, expanding, or eliminating the TRID Rule…

Closing Disclosure NMLS Number for Different MLO

Closing Disclosure NMLS Number for Different MLO

Adam Witmer
Regulation Z, SAFE Act, TRID

In this Compliance Clip (video), Adam explains what NMLS should go on the Closing Disclosure when one lender issued the Loan Estimate, but a different loan officer is now assigned to the loan. This situation can be tricky for financial institutions that don’t have much turnover with their lending staff. Fortunately, Adam busts out some commentary to guide the way on how to comply.

NFIP Set to Expire on November 21

Adam Witmer
Flood

As has been the case over a dozen times in the last few years, the National Flood Insurance Program’s (NFIP’s) short-term extension is set to expire unless Congress either establishes a long-term fix or just kicks the can down the road again by implementing another short-term extension. Either way, financial institutions will once again want to be prepared in the event the NFIP does lapse. The current NFIP extension is set to expire at midnight on Thursday, November 21, 2019. For information on what to do in the event of a lapse, you can…

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