Overdrafts Are on the Agenda!
Wondering what the future holds for overdrafts? New guidance? New Regulations? It may still be too soon for an answer but we’ll soon have an update. The Consumer Financial Protection Bureau (CFPB)...
View ArticleIntegrated Disclosures...New Forms, More Loans
If you're sitting back and relaxing because you don’t think that the new Integrated Disclosures will affect you, I want you to be sure you fully understand the scope of the Rule. The Integrated...
View ArticleRepayment Ability Risk & Requirements Matrix (Version 3.3)
We’ve updated our Repayment Ability Risk and Requirements Matrix and it’s now available on the Free Downloads page of our website. The “Equal Monthly Payments” Row in the Loan Product Requirements...
View ArticleHMDA Proposal Comment Letter
We’ve commented, you should too!! The Home Mortgage Disclosure Act proposal to expand reporting requirements is nearing the end of its comment period. Comments are due by October 29, 2014, at 11:59...
View ArticleRevisions to Integrated Disclosures Rule Proposed
The CFPB has released a proposal to revise the Integrated Disclosures Rule. Also included within the proposal is a change to the Loan Originator disclosure requirements under §1026.36 of Regulation Z....
View ArticleIntegrated Disclosures Tools
While the Integrated Disclosures Rule doesn’t go into effect until August 1, 2015, it is very important to begin preparations now. We have been reiterating this over and over the past year via this...
View ArticleAnnual Privacy Notification Changes
The CFPB has issued a Final Rule revising Regulation P; which will allow eligible institutions to meet their annual Privacy Policy notification requirements by posting their notice online if certain...
View ArticleFlood Insurance Proposal
Ever since the Homeowner Flood Insurance Affordability Act of 2014 (HFIAA) was passed we have been anxiously awaiting the promised regulatory guidance to help us implement it. Specifically, we want...
View ArticleNext BCC Compliance Forum November 25, 2014
The next BCC Compliance Forum will take place on Tuesday, November 25, 2014, from 10:30 AM - 11:30 AM (CST). This Forum will address the August 2015 Integrated Disclosures. You can email your...
View ArticleFinal Rules Allows QM "Cure"
The CFPB has issued a Final Rule that allows a creditor (or assignee) to “cure” a loan into Qualified Mortgage (QM) status after closing when points and fees exceed QM limits. Creditors or assignees...
View ArticleCFPB Mortgage Rules Readiness Guide Updated
In case you missed it, CFPB updated their Mortgage Rules Readiness Guide back in September and it can be a good resource as we get closer to the August 2015 effective date for the Integrated...
View ArticleBSA/AML: Emerging Exam Trends & Regulatory Concerns
Last month, I attend the ACAMS (Association of Certified Anti-Money Laundering Specialists) Annual AML & Financial Crime Conference in Las Vegas. The conference was full of useful information and...
View ArticleFDIC Issues Mortgage Rules Assistance Videos
The Federal Deposit Insurance Corporation (FDIC) recently announced the release of the first in a series of three new technical assistance videos developed to assist bank employees in meeting...
View Article2014 BSA/AML Examination Manual
Yesterday (December 2, 2014) the FFIEC announced the release of a revised BSA/AML Examination Manual. We will begin reviewing the changes in the coming days and weeks; however, in the meantime, you...
View ArticleFinCEN Statement on Banking MSBs
On November 10, 2014, FinCEN issued a Statement on Providing Banking Services to Money Services Businesses. Due to regulatory scrutiny, the perceived risks associated with Money Service Businesses...
View ArticleBCC Forum Changes
Banker's Compliance Consulting is excited to announce some upcoming changes to the BCC Forum. We will continue to provide quarterly guidance on the most challenging compliance issues, regulatory...
View ArticleIntegrated Disclosures: Homeowner's Insurance Paid to an Affiliate
One of the issues that we’ve struggled with in connection with the new Integrated Disclosures Rule is determining in which tolerance category to put property insurance premiums if the premium is paid...
View Article2015 CRA Threshold
The regulatory agencies have announced that the asset-size thresholds for CRA was adjusted and will take effect January 1, 2015. These thresholds determine whether an institution will be classified...
View Article2015 Regulations Z & M Threshold
The threshold to exempt consumer credit (Reg Z) and consumer leases (Reg M) from the applicable regulatory requirements will increase to $54,600 on January 1, 2015.. This is up from the 2014 threshold...
View Article2015 High Cost Mortgage Threshold
The Points & Fees Test thresholds used to determine whether a loan is a High Cost Mortgage (HCM) will increase on January 1, 2015. A loan will be considered a HCM if: • The loan amount is at least...
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