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HMDA 2018 File Format Verification Tool Now Available

By | August 14, 2018

Hot on the heels of the release of the HMDA data tables for 2017, the CFPB/BCFP has released its tool for validity checking the correctness of your Institution’s HMDA file for the calendar year 2018 data being submitted in 2019. You can find this tool at https://ffiec.cfpb.gov/tools/file‐format‐verification. The tool does exactly what it says: verifies […]

certificate of deposit

FinCEN Issues Extension of Exceptive Relief for Certificate of Deposit and Loan Renewals

By | August 9, 2018

The top BSA hotline question TCA has received in August inquired about an update to FinCEN’s May 16, 2018 Exceptive Relief (FIN‐2018‐R002) delaying the requirement to obtain a Certification of Beneficial Ownership for certificate of deposit and loan renewals. Since FinCEN considered these to be new accounts, financial institutions expressed concerns over the many challenges […]

mortgage loan application

CFPB Releases HMDA Public Data Table

By | August 8, 2018

The CFPB has released the public disclosures for HMDA data submitted for calendar year 2017. HMDA reporting institutions can go to the FFIEC HMDA Data Publication section of the CFPB website and download their disclosure tables. As the tables are no longer required to be made a part of your CRA Public File, you can […]

BAT CHAT

Model Validations—Why Do I Need a GAP Analysis?

By | July 26, 2018

The regulators are upping their game and are becoming more familiar with Automated Monitoring Systems. They are starting to push the boundaries of a model validation and their expectations for a “complete” model testing review. Some examiners are more advanced than others, but the word is being spread and soon they’ll all catch on! This […]

fair with wooden blocks

The Expectation of Exceptions in the World of Fair Lending

By | July 17, 2018

Exception reporting is not new; all banks are required to report loan policy and loan documentation exceptions for Safety and Soundness. However, a new unwritten rule is fair lending exception tracking covering pricing and underwriting exceptions on consumer loan products. Whether it’s HMDA for banks with less than or more than 500 entries, regulators want […]

trading graph

HMDA Reporting Requirements: Business Purpose Loans

By | July 11, 2018

The passing of Senate Bill 2155 adds another level of complexity to an already complex Regulation. The Bill exempts institutions that originate fewer than 500 closed‐end loans or open‐end lines of credit in each of the two preceding calendar years from reporting certain HMDA data points. This “relief” spurred the question, “What and how do […]

selecting audit button

TRID Rule Changes are on the Horizon

By | June 21, 2018

The Consumer Financial Protection Bureau (CFPB) has issued clarifications to the TILA RESPA Integrated Disclosure (TRID) rules last year. The clarifications are referred to as the 2017 Rule or the Final Rule and were published on August 11, 2017. We are alerting you again, because the mandatory compliance date is October 1, 2018. The CFPB […]

adjustable rate mortgage

Mortgage Servicing Rules – Successor in Interest Part 3 of 3

By | June 14, 2018

Effective April 19, 2018, the Successors in Interest provisions will go into effect under RESPA. It is critical that institutions have procedures developed to address potential and verified Successors in Interest, as well as train appropriate staff as to the requirements under the Regulation. Part 3 of 3 focuses on this provision; refer to Part […]

mortgage symbol

HMDA Relief is Here for Many . . . Now What?

By | June 7, 2018

Last week the compliance and risk management worlds reacted with joy over the signing of Senate Bill S. 2155. For most bankers, the passing of this bill represented the most significant regulatory relief in decades. Of noted importance was the rollback of the expanded data collection rules for the Home Mortgage Disclosure Act (HMDA). However, […]

BAT CHAT

Beneficial Ownership and Lending: Have we considered all possibilities?

By | June 6, 2018

April showers brought May flowers, or in the BSA world, beneficial ownership is finally here. The BAT has been fielding questions left and right about some of the nuances of the new CDD requirements. The BAT has speculated on the implications of CDD as the fifth pillar for years now and one thing is clear: […]

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