CBD Oil Product Retailers – What’s the Buzz? Have you seen them yet – the neon signs, plastic banners, billboards, and pop-up ads flashing “We Sell CBD!”? Since the Farm Bill passed in December 2018, the sales signs are popping …
A Lookback at Some Compliance Happenings in 2018 With the new year just beginning, it is a good idea to review some of the compliance changes that occurred in 2018: The new HMDA rules became effective on January 1, 2018. …
A Lookback at Some Compliance Happenings in 2018 Shanin L. Bachstein
PREPAID ACCOUNTS RULE – DOES THIS AFFECT OUR BANK? The Prepaid Accounts Rule has been delayed so many times that Compliance Officers have almost forgotten about it. The initial final rule was first published on October 5, 2016, delayed on …
When is a Reg B “Notice of Action” Required Regulation B requirements are intended to protect the applicant(s) from discrimination. The regulation requires financial institutions to make timely credit decisions and give an applicant distinct reasons for a denied loan …
Kay M. Scarselli When is a Reg B “Notice of Action” Required
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. …