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New Rule for Using Closing Disclosure When Resetting Tolerances
On April 26, 2018, the CFPB issued a final rule addressing utilization of a Closing Disclosure to reset tolerances under the TILA‐RESPA Integrated Disclosure Rule (TRID). Under the current regulation, a creditor may only use a Closing Disclosure to reset tolerances if there are fewer than four business days between the time the creditor is […]
FFIEC Joint Statement on Cyber Insurance
On April 10, 2018, the FFIEC issued a joint statement regarding Cyber Insurance and its role in Risk Management programs. With Cybersecurity events becoming commonplace, do you have the proper insurance to protect the bank and its assets? Although Cyber Insurance may be a part of the Risk Mitigation program, it is not the final […]
April Showers Bring May Flowers: Are you compliant with Flood?
Spring has sprung! Well, in some places anyway. Let’s make sure you don’t spring a leak in your portfolio of flood loans. Here is a spring cleaning checklist of your flood program. In general, an institution under the OCC, FRB or FDIC rules shall not make, increase, renew or extend (MIRE) any designated loan unless […]
What is the Cloud Part 2: Risk Appetite Discussion
The goal of my last article was to eliminate the mystery of the “Cloud” by breaking it into easy‐to‐understand building blocks. A key takeaway is that the cloud is not a single operating option; it has many building blocks. The blocks or choices have a significant impact on your bank’s risk exposure. To make it […]
FinCEN Issues Highly Anticipated CDD Beneficial Ownership FAQs
On April 3, 2018, FinCEN issued a frequently asked questions (FAQ) document, FIN‐2018‐G001, discussing the Beneficial Ownership Rules which go into effect on May 11, 2018. The FAQ addresses the following topics, among others: Beneficial Ownership Threshold Interaction of the beneficial ownership threshold with other AML program obligations Collection of beneficial ownership information for direct […]
HUD Issues Revised SCRA Notice
Thanks to an eagle‐eyed client for sharing with us a best‐kept secret that HUD released an updated SCRA Notice. As you know, the old form expired in December 2017. From what we can tell, the only changes to the notice are dates and the reference to 50 USC 3901‐4403, which was changed from the former […]
CRA Celebrated its 40th Year—Look for Greater Emphasis on Community Development Efforts
The Community Reinvestment Act (CRA) celebrated its 40th anniversary in 2017. The Act was established to ensure banks were meeting the credit needs of the community they designated as their assessment or market area, which often was a circle around their branches. Passing a CRA exam was less troublesome since bankers only had to be […]
CFPB Issues Updated Prepaid Card Compliance Guide
On March 13, 2018, the CFPB issued an updated Small Entity Compliance Guide (SEG) to incorporate recent 2018 changes to the Regulation E Prepaid Card rules which take effect on April 1, 2019. The Bureau released guidance for completing the short‐form disclosure for prepaid accounts, which includes not only a line‐by‐line how‐to but specifics on […]
HMDA Reporting for Loans Secured by Multiple Properties
We have received numerous questions about how to report multiple properties on the HMDA LAR for 2018. Quite frankly, it can be very confusing because some fields are reported on the property securing the loan and other fields are reported on the transaction. The commentary for §1003.4(a)(9) – 2 states the following: MULTIPLE PROPERTIES WITH […]
HMDA: Getting it Right Lives Again!
On February 21, 2018, the FFIEC released a revised HMDA: Getting It Right guide (GIR) for Regulation C changes which took effect on January 1, 2018. The GIR is in the same format as previous guides and it includes the regulation, appendices and commentary in 12 CFR §1002 plus the CFPB tools. The GIR is […]
