Do you ever have trouble finding answers to your compliance
questions? Do you get stuck and can’t
figure out what box to check or what disclosure to give? Do you just want to run an idea by someone or
need advice on how to handle an issue? If so, where or who do you turn to for
We all need a “lifeline” sometimes and Banker’s Compliance
Consulting can be that for you. We offer
phone/email support for your burning compliance questions and provide
consultation on best practices and the latest regulatory issues. Reaching out to an expert not only helps you
save valuable time but it also gives you peace of mind!
We believe in simplicity, so getting set up is easy! Just contact our office and let us know you’d
like to be a phone/email client. All we
need is your contact information and billing address. Once you’re set up, simply email your
question to email@example.com
or call us at 800-847-1653 and your question will be routed to one of our
compliance experts. Our goal is to get
you an answer within four hours (during normal business hours). Your time is valuable so we don’t want you to
wait for answers!
Billing for phone/email questions is based on a prorated,
hourly rate for the time spent on your question. This may include research time, time on the
phone, time for email communication, etc.
If your question takes 10 minutes, you only pay for 10 minutes, nothing
more. Invoices are sent out quarterly
and include a short summary of each question and the answer given, who we
talked to, that date, and the time spent.
We also offer phone/email retainer packages. These are based on many different factors, so
please contact our office for more information.
We’d be happy to answer any questions you might have
regarding our phone/email support. If
you have not tried this service, we believe it will sell itself. Ask us about a complimentary call and then,
get signed up!
We’d love to be your partner so feel free to contact us any
Be sure to JOIN US on February 18, 2020, for our webinar, “Regulation CC”.
Are Regulation CC gives you the ability to delay the availability of funds deposited into a transaction account but all of the rules can get quite confusing. There are “case-by-case” delays and “exception” delays which each have different requirements. There are certain deposits you can delay and others you can’t. There are times you need to make funds available by the next business day, the second business day or by the seventh business day. Sometimes you need a reason to delay and other times you don’t, and don’t forget about notification requirements. On July 1, 2020, changes will also take effect that will increase the amounts you need to make available in certain cases. Let us make it clear as we train you on these requirements in plain English.
Click on the video to listen to David explain more.
BONUS!! After the one-hour Regulation CC webinar is complete, we will immediately provide you with an additional 10 minutes of training devoted only to what your tellers and operational personnel need to know. You can have them sit in on the last 10 minutes or play it back to them at a later time. This valuable bonus training is only available to those that register for the one-hour webinar.
In our November 2019 Magazine, we informed you of the fact that FinCEN had changed their Currency Transaction
Report instructions (CTR
XML Schema User Guide) and the corresponding answer to Question #16
in their CTR FAQs, in regard to reporting a conductor in Part I when more than
one role applies to that conductor.
have since learned that FinCEN updated
their CTR XML Schema User Guide again, without public notice. This change relates to completing the Multiple Transaction box in Part I.
Initially, FinCEN’s instructions stated that “multiple transactions” include ALL
transactions, even if they were not reportable. FinCEN’s example under the
previous instructions stated:
Item 3 Multiple transactions: If a customer makes a $12,000 deposit and a $300 withdrawal, box 3 will be checked even though only $12,000 is reportable. This applies when multiple Part I sections with different Item 2 person types are filed on the same person. Box 3 will be checked in all Part I sections on that person.
The revised instructions have reversed that position and they now state:
Item 3 Multiple transactions: Check Item 3 if multiple cash transactions of any amount totaling more than $10,000 as cash in or more than $10,000 as cash out (cash in and cash out transactions should not be combined) were conducted in a single business day by or for the person recorded in Part I. For example, if a customer makes a $12,000 deposit and a $300 deposit on the same day, item 3 should be checked. However, if a customer makes a $12,000 deposit and $300 withdrawal, item 3 should not be checked. Item 3 “Multiple transactions” is related to, but not the same as, the Item 24 “Aggregated transactions.” Whereas Item 3 should be checked each time multiple transactions are reported as a single transaction, the Item 24 option “Aggregated transaction” should only be checked when all the specific conditions underlying that option have been satisfied.
Make sure you share this information with those personnel in your institution that are responsible for completing CTRs.
With 2020 still feeling pretty new, do you ever start thinking, “What did I forget”? One thing that can slip through the cracks are the regulatory threshold changes that generally take effect on January 1st each year. These thresholds are used to determine whether certain compliance requirements apply to your financial institution.
Here’s a quick list (not all-inclusive) of some common ones:
Loan Amount Exemption to determine if certain
loans are subject to Regulation Z
High-Cost Mortgage (Points & Fees)
Loan Amount Exemption for special appraisal
requirements on Higher-Priced Mortgage Loans
Qualified Mortgage (Points & Fees)
Qualified Mortgage (Small Creditor)
The asset-size threshold is one piece to
determining if your financial institution is subject to HMDA.
Asset-size thresholds for small, intermediate
small and large banks/savings institutions.
As we look ahead to 2020, we wanted to let you know that
we’ve updated some of the Free
Lending Tools available on our website:
Version 4.5 of the TIL: Repayment Ability and Risk Requirements Rule is now available to help you comply with the Ability to Repay/Qualified Mortgage Rule. It has been updated to reflect the adjusted points and fees amounts for 2020.
Version 3.0 of the HMDA Volume Test Chart is available to reflect that the temporary coverage threshold for open-end credit (500) has been extended until January 2022.
Version 3.2 of the HMDA Data Reporting Guide is also available. In addition to some technical updates, we have updated the Small Filer requirements for the property address and property location fields.