Reporting Director Overdrafts for Reg O

Reporting Director Overdrafts for Reg O

Adam Witmer
Regulation O

In this Compliance Clip (video), Adam discusses the overdraft restrictions for directors and executive officers under Regulation O. This video answer the question of whether or not it is a violation of Reg O when a director would have overdrawn his account by $5,000 if the bank had not returned the check for the director. Adam answers this question by diving into the requirements of Regulation O.

CFPB Issues Proposal on Remittance Rule

Adam Witmer
Regulatory Update

Consistent with their Fall 2019 rulemaking agenda, the CFPB on 12/3/19 announced a Notice of Proposed Rulemaking (NPRM) relating to remittance transfers. As a background, the remittance transfer rules generally require companies that provide remittance transfers in the normal course of business to disclose to consumers certain fees and the exchange rates that apply to transfers. The current remittance transfer rule also includes an exception for certain credit unions and banks where they are permitted to estimate certain fee and exchange rate information instead of providing exact amounts.  This exception, however, is set to expire in July of 2020.

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…

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