October 2, 2017 8:00 am
By Cody Roberts, CRCM When we bankers open accounts, we are always told to “check the OFAC list”. This happens in all departments – deposits, loans, and even trust. But what exactly is the OFAC list? The Office of Foreign Assets Control (OFAC) is a department of the U.S. Treasury that administers and enforces economic… View Article

More on HMDA

September 18, 2017 12:03 pm
By Elva M. Coffey-Sears, CRCM, CRP On August 23 the CFPB published amendments to the 2015 HMDA Final Rule. These amendments supplement the 2015 amendments, most of which are scheduled to go into effect in January 2018. The amendments impact institutional and transactional coverage, clarify key terms, provide guidance for reporting demographic information, establish transition… View Article


September 5, 2017 8:46 am
By Gina Ellis, CRCM The Federal Financial Examination Council (FFIEC) 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, the testing procedures described in the guidance will be used by the regulatory agencies to validate… View Article

What Does a FEMA Suspension of Community Eligibility Mean?

August 21, 2017 8:41 am
  By Cody Roberts As compliance professionals, we constantly get updates and alerts from a variety of sources. Periodically, we get notices of a “Suspension of Community Eligibility” from Federal Emergency Management Agency (FEMA) regarding flood insurance. However, have you ever wondered what this means or how it affects your bank and your customers? Background… View Article

Final Rule on Arbitration Agreements (or Maybe Not)

August 7, 2017 9:04 am
By Elva M. Coffey-Sears, CRCM, CRP The Dodd-Frank Act authorized the Bureau to conduct a study of arbitration and, if the study found that rules were in the public interest and for the protection of consumer, to implement regulations, consistent with the findings of the study, restricting or prohibiting arbitration. According to the CFPB, the… View Article

FinCEN Changes to the Currency Transaction Report (CTR)

July 24, 2017 9:17 am
By Gina Ellis, CRCM The New Currency Transaction Report FinCEN has announced changes to the CTR filing form and is targeting August 15, 2017 as the date the changed forms will be available for discrete filers. Effective May 31, 2018, the BSA E-filing system will only accept the updated CTR discrete form. If discrete filers… View Article

Loan and Deposit Automation

July 10, 2017 8:42 am
By Benjy Cook, President   American Bank Systems (ABS) has been in the loan and deposit automation business since 1987 when we released Loan Calc, our widely accepted lending documentation system for impact printers. In 1989 ABS revamped the system to utilize laser printer technology on the newly released HP Laser Jet that printed on… View Article


June 26, 2017 8:39 am
By Cody Roberts, CRCM   A bank compliance officer hears many things in the bank–many of which contain expletives. In this role, there are a few things you almost never hear (but wish you did). Loan officers asking you for a regulatory clarification on “creative financing” prior to closing. Employees thanking you for training on… View Article

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