"Nobody Should be Surprised by This"
When 2010 RESPA changes were on the horizon, the industry clung to the promise of enforcement leniency as we adapted to new concepts and forms. There’s no such pledge by the CFPB with this round of...
View Article30-Day Wait on Flood Insurance Policies
Flood Insurance rules are not easy and we still see both bankers and insurance agents that don’t know the rules. One common instance is regarding the 30-day waiting period for flood insurance. You...
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HMDA Changes: 2016 or 2017?
The wait is over. If you’ve been on the edge of your seat waiting to see if the proposed HMDA changes will take effect in January, you can breathe a sigh of relief. We had a hunch this would be the...
View Article"Toolkit" to Replace Settlement Cost Booklet
The CFPB recently announced the release of the “Your Home Loan Toolkit”, which is intended to be a step-by-step guide to help applicants throughout the mortgage loan process. This Toolkit is required...
View ArticleSendoff of a Friend
Sometimes in life we have to say “goodbye”. Unfortunately, I have to announce the departure of Bob Sutton from Banker’s Compliance Consulting. Fortunately, Bob will be staying in our industry by...
View ArticleRegulation Z Coverage Change
Under today's rules, credit extended to anything other than a natural person is exempt from Regulation Z requirements. However, on August 1, 2015, a key change will go into effect. This change, found...
View ArticleSCRA Policy & Procedures
As we mentioned in our May Newsletter, we have developed a sample Servicemember’s Civil Relief Act Policy. We have also included, with the policy, sample SCRA procedures. The sample Policy is a...
View ArticleIntegrated Disclosures Compliance Timeline (Version 1.2)
We’ve updated our Integrated Disclosures Compliance Timeline which can be found on the Integrated Disclosures Resources page of our website. Specifically, we removed the reference that a revised Loan...
View ArticleStandard Flood Hazard Determination Form Expired May 30, 2015
Just in case you missed it, the existing Standard Flood Hazard Determination Form (FEMA form 086-0-32) expired on May 30, 2015. Until a new form becomes available, bank's can continue to use the...
View ArticleCFPB Offering a "Sensitive" Approach to Integrated Disclosures
A June 3, 2015, blog post from the CFPB indicates they plan to be “sensitive” to those entities that have put forth a good faith effort to be in compliance with the Integrated Disclosure requirements....
View ArticleFDIC on Originator Compensation
The FDIC recently indicated that it’s still seeing banks without written policies and procedures for compliance with the Loan Originator Compensation Rule under §1026.36. This section requires written...
View ArticleIntegrated Disclosures Delayed
The CFPB announced yesterday that they will issue a proposal to delay the effective date of the Integrated Disclosures Rule to October 1, 2015. Apparently, there was an administrative error which...
View ArticleFlood Insurance Final Rule Issued
On June 22, the Agencies announced a joint final rule that implements certain provisions of the both the Homeowner Flood Insurance Affordability Act and Biggert-Waters Flood Insurance Reform Act. A...
View ArticleFinCEN to Issue Final CDD Rules in August
According to a recent ACAMS publication, the White House budget office has announced the final version of the July 2014 proposed rule on beneficial ownership will be issued in August. The proposal...
View ArticleReal Estate Checklists Version 2.0
We are pleased to announce that we have revised our Real Estate Checklists to include the Integrated Disclosure requirements (Version 2.0). These checklists will look a little different than they have...
View ArticleReal Estate Matrix 9.4 - HPML Appraisal Requirement Change Effective 7-18-15
If you make Higher-Priced Mortgage Loans (HPML) secured by manufactured homes, there is a change in the appraisal requirements going into effect on July 18th that you need to be aware of. Currently,...
View ArticleIt's Official: TRID Effective October 3rd
Yesterday, the CFPB issued a Final Rule which officially delays the effective date of the Integrated Disclosures Rule to October 3, 2015. Regardless of the reasons for the delay, you won’t find too...
View ArticleFinCEN to Enhance Secure Information Sharing System
FinCEN plans to make changes to its Secure Information Sharing System (SISS) in late September of this year. Some of the changes include: •New design intended to be more user-friendly •New password...
View ArticleIntegrated Disclosures: Real Estate Matrix 10.0
Just a heads up that we've removed the “Draft” reference on Version 10.0 of our Real Estate Matrix. Version 10.0 is to be used for applications taken on or after October 3rd, which is the effective...
View ArticleWith One Goodbye Comes a Hello
Banker’s Compliance Consulting is saddened to announce the farewell of our long time Office Manager Christy Bosak. After 16 years of loyal service, Christy will no longer be with us. We cannot wait to...
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