Overview Video Added for Fair Lending Bootcamp

Adam Witmer

We have added an overview video that explains what is included in our new Fair Lending Bootcamp. This video runs nearly 10 minutes while Adam explains what is covered in the program and what attendees can expect out of this full-day virtual seminar. The Fair Lending Bootcamp is available on-demand and can be viewed as soon as it is purchased. The new overview video can be viewed at www.compliancecohort.com/fair-lending-bootcamp

CFPB Proposes to Delay New General QM Rule

Adam Witmer
Regulatory Update, Regulation Z

On 3/3/21, the CFPB announced the release of a proposed rulemaking to delay the recently set mandatory compliance date of the General Qualified Mortgage (QM) final rule from July 1, 2021 to October 1, 2022. The CFPB states they are proposing to extend the compliance date to ensure homeowners struggling with the financial impacts of the COVID-19 pandemic have the options they need.

CFPB Sues Payment Processor

Adam Witmer
Regulatory Update

On 3/3/21, the CFPB announced that they had filed a lawsuit against a payment processor and its founder for knowingly processing payments for companies engaged in internet-based technical-support fraud. The CFPB alleges that between 2016 and 2018, Howard and BrightSpeed knowingly processed payments for client companies that purported to offer technical-support services and products over the internet, but instead tricked consumers, often older Americans, into purchasing expensive and unnecessary antivirus software or services.

FFIEC Updates BSA Exam Manual

Adam Witmer
BSA, Regulatory Update, Compliance Management

In February of 2021, the FFIEC released the second round of what appears to be an overhaul of the BSA/AML Exam Manual. The February 2021 revisions include updates to four sections including and introduction section to the section on assessing compliance with BSA regulatory requirements, and sections on customer identification programs, currency transaction reporting, and transactions of exempt persons.

VIDEO: What is Overt Evidence of Disparate Treatment?

VIDEO: What is Overt Evidence of Disparate Treatment?

Adam Witmer
Fair Lending

In this Compliance Clip (video), Adam explains how a lender could end up with overt evidence of disparate treatment. This video takes just 7 minutes to view and can be shared with your lending team or others in your organization who need to understand fair lending rules and regulations. And be sure to watch our for Adam’s alter ego lender personality in this video…

FACT CHECK: Is the New URLA Mandatory on March 1?

Adam Witmer
Regulatory Update

Over the last few weeks, we have seen several questions regarding the new Uniform Residential Loan Application (URLA) and whether or not the new version must be used on March 1, 2021. Apparently, some consulting firms are sending marketing material that says the new URLA has mandatory use on March 1, 2021.

Our conclusion is that this statement is only partially correct.

FinCEN Advisory on COVID-19 Economic Impact Payments

Adam Witmer
BSA, Regulatory Update

On 2/24/2021, the Financial Crimes Enforcement Network (FinCEN) issued Advisory FIN-2021-A002 that discusses detecting, and reporting financial crimes related to Economic Impact Payments. The advisory contains descriptions of EIP fraud, 14 associated red flag indicators, and information on reporting suspicious activity, and is part of a series published by FinCEN on COVID-19-related frauds and criminal activity.

CFPB To Reconsider QM Final Rules

Adam Witmer
Regulatory Update, Regulation Z

On 2/23/21, the CFPB issued a statement that they are considering whether to initiate a rulemaking to revisit the recent Seasoned QM Final Rule. If it does, the CFPB stated that it expects it will consider whether “any potential final rule revoking or amending the Seasoned QM Final Rule should affect covered transactions for which an application was received during the period from March 1, 2021, until the effective date of such a final rule.” Additionally, the CFPB announced that they intend to issue a proposed rule that would delay the July 1, 2021 mandatory compliance date of the General QM Final Rule. If this upcoming proposed rule becomes finalized, creditors would have a choice to use either the current GM QM loan definition or the revised GM QM loan definition for applications received from March 1, 2021 through the extended mandatory compliance date (unless a GSE ceases to operate under conservatorship prior to the extended mandatory compliance date).

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