New Flood FAQs Proposed

Adam Witmer
Regulatory Update, Flood

On 6/26/2020, the OCC, Federal Reserve, FDIC, Farm Credit Administration, and the NCUA issued a joint proposal to update the interagency flood FAQs. If issued as proposed, these revisions would be the first updates to the Interagency Questions and Answer Regarding Flood Insurance since they were last updated in 2011.

As you might recall, there have been several updates to flood insurance rules since 2011 including the Biggert-Waters Flood Insurance Reform Act of 2012, the Homeowner Flood Insurance Affordability Act of 2014, interagency guidance on the detached structure exemption, rules on the escrow of flood insurance premiums, and private flood insurance guidance. In addition to updating the questions and answers to align with most of the current flood insurance laws and guidance, the proposal would also…

Newly Exempt from HMDA?

Adam Witmer

If you are newly exempt from HMDA this week, don’t forget that you need to transition to collecting GMI under Regulation B. In other words, if you don’t collect DI under HMDA, you still have to collect GMI under Regulation B. For more information on transitioning to a non-HMDA bank, check out our class on this topic at https://www.compliancecohort.com/hmda-july-2020.

BSA Bootcamp On Sale Through Wednesday

Adam Witmer

Our BSA Bootcamp is on sale through next Wednesday, July 1, 2020. This online class is a comprehensive BSA/AML training program that can be completed from the comfort of your office (or home!) as it is delivered in our “virtual classroom” video presentation - so we can bring the seminar to you. Twice the length of a typical webinar, the BSA Bootcamp runs around 3 ½ hours and takes a deep dive into the core elements of BSA rules that any BSA/AML professional should know and understand. This program is a great way to get comprehensive BSA training in for 2020 and satisfy your examiners during your next exam. We don’t offer a discount on the BSA Bootcamp very often, so if you were considering an online option for your BSA training this year, be sure to take advantage of this price while you can. (Note: Feel free to share this with your BSA Officer and/or BSA team as non-members can purchase this program too).

Interagency Examiner Guidance for COVID-19

Adam Witmer
Regulatory Update

On 6/23/2020, the joint regulators issued interagency examiner guidance for assessing the safety and soundness of financial institutions considering the effect of the COVID-19 pandemic on institutions. The guidance states that the purpose is to outline the supervisory principles for assessing the safety and soundness of institutions given the ongoing impact of the COVID-19 pandemic. In assessing an institution under the principles in this document, the joint guidance explains that examiners will consider the institution’s asset size, complexity, and risk profile, as well as the industry and business focus of its customers and that examiners will consider the unique, evolving, and potentially long-term nature of the issues confronting institutions and exercise appropriate flexibility in their supervisory response.

CFPB Interpretive Rule for Determining Underserved Areas

Adam Witmer
Regulatory Update, Regulation Z

On 6/23/2020, the CFPB issued an interpretive rule to provide guidance to creditors information on the way in which the CFPB determines which counties qualify as “underserved” for a given calendar year. The CFPB’s list of rural and underserved counties and areas is used by financial institutions for two main purposes: 1) for an exemption from the requirement to establish an escrow account for higher-priced mortgage loans and 2) to qualify for the ability to originate balloon-payment qualified mortgages and balloon-payment high cost mortgages.

CFPB Announces Pilot Program for Issuing Advisory Opinions

Adam Witmer
Regulatory Update

On 6/18/2020, the CFPB announced the establishment of a new pilot advisory opinion program. In their release, the CFPB explains that they are establishing this pilot program in response to feedback received from external stakeholders encouraging the Bureau to provide written guidance in cases of regulatory uncertainty. Specifically, the CFPB states they are establishing the advisory opinion pilot program to provide guidance with interpretive content that is:

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