BSG Blog
Addressing Upcoming Changes in HMDA
Directed by the Dodd Frank Act-A Two Part Series
Part One: The “Known-Knowns”
In August of 2014, the CFPB released it proposed changes to the Home Mortgage Disclosure Act (“HMDA”) (Regulation C). The comment period for these changes ended in October of 2014 and aahe final rule is scheduled for July of 2015. Of course it is impossible to predict exactly what the changes will be, but to paraphrase a speech from Donald Rumsfeld, there are some known-knowns when it comes to these changes.
Changes in Community Reinvestment Act Questions and Answers May bring Some Welcome News
One of the more difficult tasks that our clients must accomplish is to try to meet the community development and community service tests in the Community reinvestment Act (“CRA”). For many community banks the opportunities to do community service that qualifies under the requirements of the CRA are very limited.
What Your Declines and Withdrawals Say About You
The regular review of the declines and withdrawals is a common practice at financial institutions. In fact a secondary review of decline notices and withdrawals is a standard part of a strong compliance management program. The typical review includes making sure that notices are given on a timely basis, to the appropriate parties and that the notices include the proper reasons for the declination.
Your First TRID Examination-What the Regulators Expect
There has been a great deal of attention paid to the idea that the TILA / RESPA Integrated Disclosure Rules (“TRID”) will soon be implemented. These rules combine the Good Faith Estimate from RESPA and Truth in Lending disclosures from Regulation Z which are both currently required for a mortgage loan. Information that fully describes the requirements of these rules is readily available.
Strategic Planning for Compliance
In the Summer, 2015 issue of Supervisory Insights, the FDIC focuses on the idea of strategic planning for banks in a shifting earnings environment.[1] While this article addresses the need for overall strategic planning at banks, it brings to mind the idea that the compliance program at your bank specifically should undergo strategic planning.
Why don’t the Regulators Just Understand?
To paraphrase the great Will Smith, actor and rapper extraordinaire – sometimes it just seems like “regulators just don’t understand”! Have you ever felt like you were being singled out during an examination? You are most certainly not alone! Despite the fact that it seems like the examiners often don’t understand the fact that banks are for-profit organization…
Conducting a Validation of Your BSA/AML software – Part 1
A two part series | Since the beginning of crime, there has been a need to hide the ill-gotten gains of criminal activity. Early bad guys held their loot in caves. Later, treasure chest provided a means of hiding criminal wealth. However, despite the form that ancient loot took, the goal was and has always been to reduce assets to currency so that it can be used…
B2B Lenders Versus Community Banks: The Best Service Strategy Wins
There is a perceived inability or unwillingness on the part of banks to make small and medium enterprise (SME) loans. Entering the phrase “small business loans” into an internet search engine will return any number of horror stories about banks having greatly reduced or even stopped making small business loans, or banks who took a customer’s application, fiddled…
Getting to the Root of the Problem- An important Step to Strong Compliance
Getting to the Root of the Problem- An important Step to Strong Compliance
The compliance examiners are coming! It is time to get everything together to prepare for the onslaught right? Time to review every consumer loan that has been made and every account that has been opened in the last 12 months, right? Not necessarily! The fact of the matter is that the c…
Commercial Banks Need Compliance Too!
“Commercial” Banks Need Compliance Programs Too! One of the things that we often hear from community banks is that the cost of compliance is high…