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HMDA Reporting for Loans Secured by Multiple Properties
We have received numerous questions about how to report multiple properties on the HMDA LAR for 2018. Quite frankly, it can be very confusing because some fields are reported on the property securing the loan and other fields are reported on the transaction. The commentary for §1003.4(a)(9) – 2 states the following: MULTIPLE PROPERTIES WITH …
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HMDA: Getting it Right Lives Again!
On February 21, 2018, the FFIEC released a revised HMDA: Getting It Right guide (GIR) for Regulation C changes which took effect on January 1, 2018. The GIR is in the same format as previous guides and it includes the regulation, appendices and commentary in 12 CFR §1002 plus the CFPB tools. The GIR is …
Making SAR Narratives Error‐Proof
Each SAR field is entered into FinCEN’s searchable database, so law enforcement can pull information or run inquires to aid investigations into financial and other illicit crimes. That’s why SARs are crucial. The law enforcement agencies are your audience and they need to know the whole “story” since they were not actively involved in the …
Is Regulatory Relief Finally Happening?
You may think the subject of regulatory relief is not a popular one here at TCA. However, even a firm which specializes in providing solutions to manage regulatory compliance risk understands the importance of commonsense regulations, especially for community banks. We watch the legislative agenda carefully for indicators of change, but if I had a …
Avoid Regulation DD Pitfalls When Disclosing Introductory Rates
Retail bankers have to confront a robust stock market, aggressive deposit acquisition strategies from growing firms, and maybe more than three Fed rate increases coming in 2018. Increasingly more creative methods are being used to attract deposit dollars. One such method is offering higher introductory rate products to catch attention while still holding down the …
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FinCEN Finalizes New SAR
FinCEN announced updates to the Suspicious Activity Report (SAR) filing format in a notice to e‐filers. The announcement says that the revisions adhere to the changes listed in FinCEN’s February 2, 2017 Federal Register notice and will be live in June 2018. In these new filings, batch submissions will have to be made in an …
Combating Elder Financial Exploitation
On August 30, 2017, FinCEN issued a memorandum titled “Memorandum on Financial Institution and Law Enforcement Efforts to Combat Elder Financial Exploitation.” Elder Financial Exploitation is the improper use of an older person’s funds or assets. Assets can also include the older person’s property or belongings. When an older person is being exploited, it often …
CFPB Releases HMDA‐LAR Reporting Tool
On Thursday, February 1, 2018, the Consumer Financial Protection Bureau (CFPB) released a statement indicating that the 2018 HMDA LAR Formatting Tool is now available. The tool, which is available here, is for use by those institutions not currently using an automated system for processing their HMDA LAR. Under the new HMDA reporting rules, an …
What is the Cloud?
It’s not atmospheric, but the term is banner‐like: sky-borne and all powerful. Before we can discuss the hot topic of shared multi-tenant environment risk in our next article, we need to take a step back and address, “What is Cloud Computing?” Sure, the cloud is out there, somewhere in the unknown, or most likely hidden …
Government Shutdown—National Flood Insurance Program Affected
Washington pulled through with a temporary compromise on extending government funding on Monday, thereby continuing to fund many “non‐essential” services and programs – one of which is the National Flood Insurance Program (NFIP). However, this provides us with a three week window and if additional compromises or an agreement is not made we may find …
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