Does a Creditor Need to Share Closing Disclosures with Third Parties? Often times as a settlement is coming down to the wire, there are pressures to share the Closing Disclosure with a realtor or broker involved in the transaction. Why …
Does a Creditor Need to Share Closing Disclosures with Third Parties Evelyn I. Dehmey
Credit Reports and Public Records As a result of a settlement between the three national consumer credit reporting companies and 30 state attorneys general (National Consumer Assistance Plan or NCAP), the credit bureaus were required to increase the accuracy of …
Impact of HMDA Changes to CRA Exams On November 24, 2017 the agencies issued revisions to Regulation BB – Community Reinvestment Act – to bring consistency between HMDA and CRA definitions. The past CRA definition for a Mortgage Loan was …
ECCHO, ECK, ECI – What the “E” is happening with electronic check processing? As a result of the days following 9/11 and commerce nearly coming to a complete stop, the Federal Reserve Board (FRB) realized the need for electronic check …
Cindy Tice ECCHO ECI – What the “E” is happening with electronic check processing ECK Evelyn I. Dehmey
CRA Public File – April 1 Deadline is Looming! Now that your 2017 HMDA LAR is filed (by March 1), there’s another deadline looming – Your CRA Public File must be current as of April 1 of each year per …
CRA Public File - April 1 Deadline is Looming Evelyn I. Dehmey
Do Successor in Interest Rules Apply to My Bank? Successor in interest rules take effect on April 19, 2018 and many are still wondering if and how they apply to them if they are not a “large servicer.” A “small …
If it’s Tax Season it also means PA Escheat Season! With the April 18th reporting deadlines just on the horizon, many institutions are in process of scrubbing their dormant accounts for potential escheat processing. If you fail to report timely, …
Evelyn I. Dehmey If it’s Tax Season it also means PA Escheat Season
WHAT’S ALL THE CHATTER – REMA VS ASSESSMENT AREA? There was a time when all we needed to worry about for CRA (Community Reinvestment Act) compliance was defining the Bank’s Assessment Area – the geographic area by which the bank …
WHEN DO I HAVE AN APPLICATION? This is a frequently asked question in compliance circles and the answer is the elusive “It depends!” There are different definitions of “application” in various regulations depending on the context of the regulation. For …
ECOA Equal Credit Opportunity Act Evelyn I. Dehmey HMDA Regulation B
What’s in Your Compliance Management System (CMS)? By Evie Dehmey On November 14, 2016, the FFIEC issued “Uniform Interagency Consumer Compliance Rating System” guidance, which became effective on March 1, 2017. This guidance is intended to update regulatory standards since …