New URLA Implementation Date Set

Adam Witmer
Regulatory Update

On December 18, 2019, Fannie Mae and Freddie Mac published a revised implementation timeline for the redesigned Uniform Residential Loan Application (URLA) as well as updated automated underwriting systems (AUS). Starting on September 1, 2020, all lenders may begin using the redesigned URLA and may also submit loan applications to the new AUS production environment. Prior to this time, testing and limited use (during a “test and learn” period) will be available for some lenders. By November 1, 2020, all lenders must use the redesigned URAL and submit loan applications to the new AUS production environment. In addition to announcing the implementation dates of the URLA and new AUS, the…

CFPB Adds TRID Guidance

Adam Witmer
TRID, Regulatory Update

On 12/18/19, the CFPB released two additional TRID guides regarding disclosures for construction-only and construction-permanent loans. The guidance can be viewed in either a combined guide or a separate guide, and provides examples based on common questions received by the Bureau.

What is Money Laundering?

Adam Witmer
BSA

In this Compliance Clip (video), Adam provides a simple explanation of money laundering. As BSA and AML rules can often be difficult to explain, this video provides a quick overview of money laundering in simple and easy to understand language.

FDIC Updates Consumer Compliance Exam Manual

Adam Witmer
Regulatory Update

Earlier this month, the FDIC updated their Consumer Compliance Exam Manual by adding a section on Disclosure Requirements for Sweep Accounts. This new section adds just a half a page of instruction and is intended to assist examiners in the review of disclosure requirements that apply to all sweep account contracts, which require financial institutions to prominently disclose whether swept funds are deposits and the status of the swept funds if the institution were to fail. The updated version…

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.

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