Clarification on Force Placed Flood Insurance Premiums

June 12, 2017 8:39 am
By Elva Coffey-Sears, CRCM, CRP Early last year, the industry became aware that interagency guidance had been provided to examination staff regarding the impact on compliance with flood regulations when force placed flood insurance premiums are added to a loan balance. Specifically, this guidance indicated that the addition of the premiums to the loan balance… View Article

BSA Report Oblivion? Not so fast!

May 19, 2017 8:58 am
By Cody Roberts, CRCM   BSA Report Oblivion is seemingly the place all BSA reports, such as SARs and CTRs, go once a financial institution files them.   Much like a black hole in space draws in all nearby matter and energy, these reports can seem to draw all of a BSA officer’s energy and time,… View Article

Managing Regulatory Change

May 3, 2017 8:44 am
By Elva Coffey-Sears, CRCM Managing regulatory change has never been more challenging than it is today. On a daily basis, we are bombarded with news reports that the new administration will roll back recent regulatory changes. Thus far, it has mandated reviews of regulations implemented in response to the 2008 financial crisis, ordered delays in… View Article

CFPB Proposes Amendments to Regulation B

April 17, 2017 4:32 pm
By Gina Ellis, CRCM On April 4, 2017, the Consumer Financial Protection Bureau (CFPB) proposed amendments to Regulation B, the Equal Credit Opportunity Act (ECOA), to conform with the requirements for collection of race and ethnicity to those found in recent revisions to Regulation C, the Home Mortgage Disclosure Act (HMDA). The proposal would make… View Article

Docs Direct/BankManager Elite

April 3, 2017 8:00 am
By Benjy Cook, President             Electronic signatures are more widely accepted today especially in consumer and real estate transactions. Borrowers become annoyed when they are asked to sign multiple times to obtain a loan. American Bank Systems’ document management system BankManager Elite has been importing electronic documents that are signed electronically for many years. With… View Article

FinCEN SAR Stats – March 2017

March 20, 2017 8:44 am
By Cody Roberts, CRCM Financial Crimes Enforcement Network (FinCEN) is a bureau of the U.S. Department of the Treasury that is designated to safeguard the financial system from illicit use, combat money laundering and promote national security through the collection, analysis, and dissemination of financial intelligence and strategic use of financial authorities. In particular, FinCEN… View Article

FDIC Changes to CRA Notice

March 6, 2017 12:24 pm
By Elva Coffey-Sears, CRCM On January 18, 2017 the regulatory agencies published amendments to the CRA regulations reflecting adjustments to the asset size thresholds used to define small bank and intermediate small bank in the Federal Register. The FDIC also included amendments to its CRA Notice requirements reflecting two technical changes regarding the manner in… View Article

OCC Reduction In Regulatory Burden

February 21, 2017 9:51 am
By Gina Ellis, CRCM On December 15, 2016, the Office of the Comptroller of the Currency (OCC) issued News Release 2016-156 removing outdated or unnecessary provisions of certain rules. Among those is the financial disclosure requirement found in 12 CFR Part 18. Specifically, Part 18 requires national banks to prepare financial disclosure statements which include… View Article

Americans with Disability Act – Back in the News

February 6, 2017 8:00 am
By Elva Coffey-Sears, CRCM The Americans with Disability Act (ADA) has had little press since it was signed into law on July 26, 1990 – at least until now. The ADA is designed to prevent discrimination against persons with disabilities and to provide them with equal access to employment, physical facilities, and goods and services… View Article

Don’t Forget about the Bank Bribery Act

January 23, 2017 8:00 am
By Cody Roberts, CRCM If you look at enforcement actions, you will see topics noted like BSA/AML, real estate lending and flood, capital adequacy, loan quality, UDAAP, and cybersecurity. The Bank Bribery Act will likely not be seen in such actions.  But this law is still in effect—and relevant. What is the Bank Bribery Act?… View Article