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

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

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

By Cody Roberts As a compliance professional, you probably have to train a number of different types of employees periodically. This may include audiences as different as loan officers, tellers, or members of the board of directors. As such, one question you must address is also one of the most difficult: how do you convince… View Article

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

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

By Gary Reed, Vice President – Customer Care Services “Thank you for calling American Bank Systems, this is Customer Care, how can I help you? Hmm… your program is locked up? Have you rebooted?” Gone are the days of simple solutions to issues called into our Customer Care team. When I first started with American… View Article

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

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

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