FinCEN 2018 Suspicious Activity Form Update

February 20, 2018 9:57 am
by Elva M. Coffey-Sears, CRCM, CRP FinCEN announced that the changes to the Suspicious Activity Report (SAR) proposed in February 2017 will be implemented and effective in June 2018. The revisions do not impose any new regulatory requirements nor change the requirements relating to suspicious activity reporting. FinCEN is removing, revising and adding new fields… View Article

National Flood Insurance Program Reauthorization

February 5, 2018 10:08 am
By Gina Ellis, CRCM The President and both houses of Congress extended the National Flood Insurance Program (NFIP) temporarily through February 8, 2018 and also authorized the Federal Emergency Management Agency (FEMA) to honor all policy related transactions inadvertently accepted during the recent government shut down that occurred between January 20-22, 2018. FEMA issued implementation… View Article

Ticket Tracker Program for CoPilot

January 22, 2018 9:49 am
By Gary Reed, Vice President – Customer Care Services Every day we have customers contact us for issues, questions, or to request enhancements for the different systems we support. Our clients can reach out to us via telephone or by e-mail. Additionally, our Co-Pilot clients can use our Ticket Tracker system. Using Ticket Tracker allows… View Article

New Year, New Thresholds

January 8, 2018 10:27 am
By Cody Roberts, CRCM If there is a new year, there must be new compliance thresholds. Annual adjustments are made to various regulatory thresholds which are based on various consumer price indexes at defined times during the year. The following is a recap of these changes for 2018. HMDA The asset-size exemption threshold for HMDA… View Article

Compliance Miscellany for End of 2017

January 3, 2018 9:49 am
by Elva M. Coffey-Sears, CRCM, CRP As 2017 winds to a close, Compliance Officers are focused on confirming readiness for the revised HMDA rule and implementing processes for the 2018 Customer Due Diligence requirements (including Beneficial Ownership). While the CFPB deals with issues relating to Mulvaney’s appointment and his 30-day moratorium on new regulations, the… View Article

2018 Customer Due Diligence Requirements, It’s Not Just About Beneficial Ownership

December 11, 2017 9:53 am
By Gina Ellis, CRCM So maybe you have completed your procedures for beneficial ownership identification or maybe you are still working on those requirements. But don’t forget another critical part of the new regulation effective May 11, 2018, will require Bank Secrecy Act (BSA) policy changes and procedures for the new “fifth pillar” customer due… View Article


November 14, 2017 10:37 am
By Gina Ellis, CRCM As we noted in an earlier blog, regulatory agencies announced the issuance of Home Mortgage Disclosure Act (HMDA) Examiner Transaction Testing Guidelines to support the evaluation of financial institutions’ compliance with HMDA’s new requirements beginning January 1, 2018. Those guidelines describe testing procedures to be used by the regulatory agencies to… View Article

CFPB Rule on Arbitration Agreements Overturned

October 30, 2017 8:43 am
By Elva M. Coffey-Sears, CRCM, CRP We reported last August that, on July 19, 2017, the CFPB published a final rule and official interpretations to regulate arbitration agreements in contracts for specified consumer financial products and services. On July 25, 2017, the House of Representatives, using the Congressional Review Act, passed a resolution to repeal… View Article