Time to Dust Off and Update Your BSA and OFAC Risk Assessment! As children starting the arduous process of composing their wish list for Santa, many financial institutions are making and preparing and receiving lists for their own end-of-year tradition …
Julie J. Mixtacki Time to Dust Off and Update Your BSA and OFAC Risk Assessment
FinCEN Releases Further Guidance for Banking Hemp-Related Business Customers While fielding the daily news and guidance about COVID-related fraud and considerations, it may have been easy to miss FinCEN’s update regarding expectations for performing due diligence for hemp-related business customers. …
FinCEN Releases Further Guidance for Banking Hemp-Related Business Customers Julie J. Mixtacki
On June 24, 2020 the FFIEC announced the availability of 2019 HMDA Disclosures. At the same time, they shared an analysis of the aggregate data submitted, comparing 2018 data with 2019 data. This helps us to understand how financial institutions …
How might HMDA Thresholds Affect Your Institution? On April 16, the CFPB announced its final rule on the thresholds for reporting closed-end and open-end loans for HMDA. The threshold for closed-end mortgage loans increased from 25 to 100 loans effective …
Evelyn I. Dehmey How might HMDA Thresholds Affect Your Institution
Are You Aware of NACHA’s New Registry Requirement? NACHA is implementing a new registry, the ACH Contact Registry, for all financial institutions involved in ACH operations. The purpose of the new registry is to allow financial institutions to interact with …
WHAT IS TIME-BARRED DEBT AND HOW DOES IT AFFECT MY BANK? On February 21, the CFPB announced a proposal to amend Regulation F – Fair Debt Collection Practices Act (FDCPA) by requiring debt collectors to make certain disclosures when collecting …
Evelyn I. Dehmey WHAT IS TIME-BARRED DEBT AND HOW DOES IT AFFECT MY BANK
Are you ready for the SECURE Act of 2019? The SECURE Act (The Setting Every Community Up for Retirement Enhancement Act) of 2019 will affect most retirement savers, for better or worse. This act has changed the required age in …
DISTINGUISHING “ABUSIVE” PRACTICES Many leading articles on the subject of the CFPB’s release of its position on “abusive” acts or practices proclaim that the CFPB has defined “abusive.” This is simply not true. The Dodd Frank Act already defined “abusive” …
WHAT’S IN YOUR LOAN REVIEW? Whether you’re a small community bank or a large regional bank, you should have a credit risk review function to analyze individual loan quality and to provide analysis of your entire portfolio quality. On October …
CRA TRACKING FOR PANDEMIC LOANS While we’re in the throes of the Covid-19 pandemic, the one thing we don’t need is more work. But it is an important season to think about how loan programs and modifications can work to …