When the FACT Act was rolled out, it took 3 years for regulators to fully implement it with regulations. It seems when we hit the “Identity Theft” sections, it took our breath away and most institutions left their focus there. …
Evelyn I. Dehmey What Can We Learn from the State Farm Case?
To help assist in ensuring your financial institution is up to date with servicing guidelines for FHLMC loans, here is a summary of some of the changes being made to the FHLMC Servicing Guide for 2019: Article prepared by Kay M. …
Kay M. Scarselli Summary of FHLMC Serving Guide updates for 2019
CRA Overhaul Coming! Bankers have been under regulatory siege for the last few years with major changes involving mortgage servicing, new TILA/RESPA disclosures, and a total HMDA overhaul – with little opportunity to influence those changes. The OCC is now …
WHAT HAPPENED TO ETHICS? Recently, the FDIC softened its approval for Section 19 approvals which is required to insure a person is employable in the financial services industry. Section 19 prohibits a person convicted of any criminal offense involving dishonesty, …
COUNTING HMDA! One of the most problematic issues we’ve encountered with HMDA is how to count open-end lines of credit for exemption and then what to report. If you follow the CFPB’s Transactional Coverage Chart at https://s3.amazonaws.com/files.consumerfinance.gov/f/documents/201709_cfpb_2018-hmda-transactional-coverage.pdf to the end, …
CFPB’s Fall 2018 Rulemaking Agenda The CFPB has been busy so far in 2018 and there is no slowing down as the year comes to an end. The following is a listing of items on the CFPB’s Fall 2018 agenda. …
Human trafficking occurs around the world on a daily basis. As a financial institution, you may be wondering how your institution can help those affected and ensure your customers are not victimized. There are two types of human trafficking within …
Privacy Fallout Everyone’s been waiting a long time for the CFPB to make the FAST Act rule concerning annual privacy notices “official” by way of regulation. Well, that happened on August 17, 2108 but there are still a few caveats. …
Take a Proactive Approach to Cryptocurrency Due Diligence and Monitoring With so many regulatory updates on your financial institution’s plate for 2018 (still having flashbacks from the beneficial ownership roll-out?), you may have overlooked one emerging higher risk trend – …
Julie J. Mixtacki Take a Proactive Approach to Cryptocurrency Due Diligence and Monitoring
Pop Quiz – Shared Branching on New Currency Transaction Report You may have noticed a new option called “Shared Branching” on the updated Currency Transaction Report (CTR) form. “Shared Branching” could only mean one thing – the customer conducted transactions …