As we continue to adjust with the evolving pandemic, FinCEN published two documents to keep awareness high. The May 18, 2020 Notice provides a current update to meet the various BSA reporting, recordkeeping and monitoring requirements. Here are a few of the key points: BSA Reporting Requirements – As noted in TCA’s earlier article BSA […]
FinCEN Guidance on Medical Scams and COVID-19 Read More »
Ever since I’ve been in banking, Congress was going to relax the six-transaction limitation from savings and money market accounts. We won’t talk about how long that’s been, but it’s been a while. All it took was a global pandemic. Bankers and consumers have gotten their wish. (Actually, the FRB has been looking at this
UPDATE: Unlimited Savings Withdrawals Are a Reality Read More »
The CFPB released a Regulation E Update regarding remittance transfers and increasing the safe harbor threshold from 100 to 500 transactions per calendar year, effective July 21, 2020. Regulation E requires remittance transfer providers to provide customers with certain disclosures and establishes cancellation and error resolution procedures for these foreign transactions. Also, the update memorialized
Big Increase to Foreign Remittance Transfer Threshold Read More »
On April 29, 2020, the Consumer Financial Protection Bureau released an interpretive ruling effective on May 4, 2020 providing rescission relief. If a consumer refinances or applies for a mortgage loan and needs funds due to the COVID-19 pandemic before the end of the waiting periods, lenders can waive and modify the waiting period for
CFPB Waives TRID and Rescission Timeframes Read More »
It’s the end of an era. I have been in audit or compliance for {shudder} over 30 years now, and in all that time have had APRWin as a constant companion to test the validity of those APRs. It’s like an old friend. The current version has been around since May 2008. APYWin isn’t quite
APRWin and APYWin Replaced with Web Versions Read More »
On April 16, 2020, the CFPB released a final rule affecting the thresholds for HMDA reporting. To assist with understanding the transition, the Bureau has published new resources and updated some existing ones: Unofficial, informal redline to reflect changes to Regulation C Executive Summary HMDA Rule Key Dates Timeline 2020-2022 HMDA institutional coverage chart, effective
HMDA Reporting Threshold Changes for 2020 and Beyond Read More »
On April 14, 2020 the OCC, FRB and FDIC issued an interim final rule effective April 17, 2020 until December 31, 2020 (comments due June 1, 2020) which will amend the agencies’ regulations requiring appraisals of real estate for certain transactions. (NOTE: This rule was finalized on October 16, 2020.) Under the interim final rule,
Agencies Release Interim Final Rule on Deferral of Appraisals/Evaluations Read More »
Today’s complex world just got a whole lot more complex with the spread of COVID-19. There are new cases daily, stores have limited hours or are closing, restaurants are restricted to carry-out, schools are closed, and many of you have decided to close your lobbies and service your customers through the drive-through or walk-up windows.
COVID-19 Business Impact: What Can You Do to Help? Read More »
In case you missed the CFPB announcements, the Bureau released two Policy Statements earlier this year. One statement addressed the prohibition on Abusive acts or practices and another notice described a new designation for some Bureau guidance, known as “Compliance Aids,” used to explain the legal status and role of guidance with that designation. Compliance
CFPB Releases Two Policy Statements Read More »
The headline reads more like the title of an action and adventure movie, but professionals who manage the day-to-day compliance with the Bank Secrecy Act know first-hand how much of an adventure their career path can take. As part of our annual BSA training, we often remind staff that the BSA carries both civil and
Bank Secrecy Act: This Time, It’s Personal! Read More »
We’re here to review your current compliance strategy and help you find A Better Way to manage risk.
