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FinCEN Issues Extension of Exceptive Relief for Certificate of Deposit and Loan Renewals
The top BSA hotline question TCA has received in August inquired about an update to FinCEN’s May 16, 2018 Exceptive Relief (FIN‐2018‐R002) delaying the requirement to obtain a Certification of Beneficial Ownership for certificate of deposit and loan renewals. Since FinCEN considered these to be new accounts, financial institutions expressed concerns over the many challenges […]
CFPB Releases HMDA Public Data Table
The CFPB has released the public disclosures for HMDA data submitted for calendar year 2017. HMDA reporting institutions can go to the FFIEC HMDA Data Publication section of the CFPB website and download their disclosure tables. As the tables are no longer required to be made a part of your CRA Public File, you can […]
Model Validations—Why Do I Need a GAP Analysis?
The regulators are upping their game and are becoming more familiar with Automated Monitoring Systems. They are starting to push the boundaries of a model validation and their expectations for a “complete” model testing review. Some examiners are more advanced than others, but the word is being spread and soon they’ll all catch on! This […]
The Expectation of Exceptions in the World of Fair Lending
Exception reporting is not new; all banks are required to report loan policy and loan documentation exceptions for Safety and Soundness. However, a new unwritten rule is fair lending exception tracking covering pricing and underwriting exceptions on consumer loan products. Whether it’s HMDA for banks with less than or more than 500 entries, regulators want […]
HMDA Reporting Requirements: Business Purpose Loans
The passing of Senate Bill 2155 adds another level of complexity to an already complex Regulation. The Bill exempts institutions that originate fewer than 500 closed‐end loans or open‐end lines of credit in each of the two preceding calendar years from reporting certain HMDA data points. This “relief” spurred the question, “What and how do […]
TRID Rule Changes are on the Horizon
The Consumer Financial Protection Bureau (CFPB) has issued clarifications to the TILA RESPA Integrated Disclosure (TRID) rules last year. The clarifications are referred to as the 2017 Rule or the Final Rule and were published on August 11, 2017. We are alerting you again, because the mandatory compliance date is October 1, 2018. The CFPB […]
Mortgage Servicing Rules – Successor in Interest Part 3 of 3
Effective April 19, 2018, the Successors in Interest provisions will go into effect under RESPA. It is critical that institutions have procedures developed to address potential and verified Successors in Interest, as well as train appropriate staff as to the requirements under the Regulation. Part 3 of 3 focuses on this provision; refer to Part […]
HMDA Relief is Here for Many . . . Now What?
Last week the compliance and risk management worlds reacted with joy over the signing of Senate Bill S. 2155. For most bankers, the passing of this bill represented the most significant regulatory relief in decades. Of noted importance was the rollback of the expanded data collection rules for the Home Mortgage Disclosure Act (HMDA). However, […]
Beneficial Ownership and Lending: Have we considered all possibilities?
April showers brought May flowers, or in the BSA world, beneficial ownership is finally here. The BAT has been fielding questions left and right about some of the nuances of the new CDD requirements. The BAT has speculated on the implications of CDD as the fifth pillar for years now and one thing is clear: […]
FinCEN issues Exceptive Relief for Certificate of Deposit and Loan Renewals
Many TCA clients have expressed concerns regarding FinCEN’s position that automatic renewals of certificates of deposits and loans are considered new accounts which require that a financial institution obtain a Certification of Beneficial Ownership for legal entity customers. Since FinCEN published the Frequently Asked Questions just one month prior to the mandatory compliance date, our […]