APOR Rates Delayed for Week Of 11/15/21

Adam Witmer
HMDA

The CFPB announced that the publication of Average Prime Offer Rates (APOR) for the week of November 15, 2021 was delayed. This information was listed at the bottom of the page containing the CFPB’s rate spread calculator. As the CFPB states that these data are now available on the Bureau’s Rate Spread Calculator above, financial institution will want to ensure they are using the accurate data for the week of 1/15/21.

Joint Statement on Mortgage Servicing Rules

Adam Witmer
Regulatory Update, Regulation Z

On 11/10/21, the joint agencies (Federal Reserve, FDIC, CFPB, NCUA, OCC, and state financial regulators) issued a joint statement to communicate to mortgage servicers the agencies’ supervisory and enforcement approach as risks associated with the Coronavirus Disease (COVID-19) pandemic continue to change. In short, the agencies explain that the flexibilities outlined in their prior joint statement issued on April 3, 2020 are no longer necessary, and, therefore, those flexibilities no longer apply.

SALE ENDING TUESDAY: Fall 2021 Quarterly Compliance Update

Adam Witmer

The “early bird” discount on our Fall 2021 Quarterly Compliance Update will be ending next Tuesday, 11/16/21. As you would expect, this program includes all of the regulatory activity from the months of July, August, and September of 2021. Included in this program is a feature section on the CFPB’s proposal for small business data reporting which is a HMDA-like rule that will be a significant burden to those required to comply - and unfortunately, it looks like this rule will apply to quite a few community banks and credit unions (including many who are not currently HMDA reporters). You can learn more about this program and see the full curriculum at www.compliancecohort.com/fall-2021-quarterly-compliance-update.

FinCEN Exchange on SAR Stats

Adam Witmer
BSA, Regulatory Update

On 11/9/21, the Financial Crimes Enforcement Network (FinCEN) announced that they convened a virtual FinCEN Exchange with members of the financial industry and law enforcement to discuss FinCEN’s analysis of suspicious activity reporting (SAR) with a transactional nexus to Alabama, Florida, Georgia, Mississippi, and South Carolina. Topics of discussion in the exchange included an analysis of certain Bank Secrecy Act (BSA) filing statistics for SARs and an analysis of SAR filings related to recent FinCEN advisories.

CFPB Guides for Consumers on Elder Financial Abuse

Adam Witmer
Regulatory Update

In early November, 2021, the Consumer Financial Protection Bureau (CFPB) released two guides to assist families and friend of people living in nursing homes and assisted living communities who may be subject to elder financial abuse. While these guides weren’t designed specifically for financial institutions, they could be a great resource for financial institutions when a customer suspects a family member or friend is subject to elder financial abuse.

CFPB Credit Report Findings for Minorities

Adam Witmer
Regulatory Update

On 11/2/2021, the CFPB released the statement, CFPB Finds Credit Report Disputes Far More Common in Majority Black and Hispanic Neighborhoods. In their release, the CFPB explains that consumers in majority Black and Hispanic neighborhoods, as well as younger consumers and those with low credit scores, are far more likely to have disputes appear on their credit reports. According to the CFPB, the new research is a part of a series of reports focusing on trends in the consumer financial marketplace, and uses data on auto loan, student loan, and credit card accounts opened between 2012 and 2019.

VIDEO: Executive Summary on CFPB Proposal for Small Business Data Collection

VIDEO: Executive Summary on CFPB Proposal for Small Business Data Collection

Adam Witmer
Compliance Management, Fair Lending, Regulation B

In this Compliance Clip (video), Adam provides a quick executive summary of the CFPB’s recent proposal to amend Regulation B, which will require small business data collection and reporting - much like HMDA - for many financial institutions. As this rule will have a significant impact on financial institutions, it is important to understand the direction this proposal is headed in regards to who might be required to report and what this rule is going to require. This video is a MUST WATCH for all compliance officer, senior lenders, and those who may be required to implement this new rule. (NOTE: Feel free to share this video with those in your team who may need to have this information as this video is free to all.)

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