Private Flood Insurance – It is not going to be that easy

Screen Shot 2019 02 07 at 12.15.53 PM - Private Flood Insurance - It is not going to be that easy
We respect your time. All you need to know in 30 Minutes.

The new private flood insurance rules are finally here!  One thing to note is that they specifically dictate that a lender cannot reject a private flood insurance policy simply because it doesn’t include the compliance aid statement. This means, you are still going to have to understand the criteria and do your due diligence when a private flood insurance policy is provided to determine whether or not you must accept it relative to the mandatory acceptance conditions.   

If you didn’t know the rules just came out or you want to learn what they are all about, you’re in luck! 

We have put together a 30-minute webinar to get you up to speed and give you everything you need to know about these new requirements.

We hope to see you there. Register today!  We can’t wait to see you there!

Jerod Moyer

What do complaints have to do with your bank’s compliance management system?

What do complaints have to do with your bank’s compliance management system? Actually, a quite a bit.  You see, your compliance management system is made up of several pillars. One of those core pillars is how you acknowledge and handle complaints. There’s no regulatory requirement to have a formalized complaint program. However, there are two things that really start to point us in that direction. Number one is the growing emphasis on regulatory expectations, for example, what your regulatory agency expects with regards to complaints when they walk through your door.  Maybe even more important, is number two.  What are your peers are doing with complaints that your examiners are see and then and then expect the same from you the next time they come in. The evolution of your peers is going a long way as to what’s being expected from bank to bank as it relates to formalized complaint programs and the acknowledgement and handling of those complaints.

So how does your complaint program stack up? Or maybe you don’t have a program and you want to know where you should start. You’re in luck!

Our team has put together a training session that is all about complaints and complaint programs, the regulatory expectations, and the best practices that go along with that. How can you access that training?  We hope to provide several different avenues, but the first is going to be at our Spring Live Event the Deposit Operations Compliance Conference. Register today and be prepared to learn about not just complaints, but all of the other hotspot areas as it relates to the deposit operations compliance area.

We can’t wait to see you there!

Jerod Moyer

Lending Update 2019


Are you looking for the latest lending compliance-related updates?  Maybe some lending hotspots areas?  Or, even the NEW private flood insurance rules? Well, if so, you’re in luck.


Today I’d like to extend an invitation to you and your team to come out and join our team as we walk you through lending hotspot areas and the latest lending requirements in a one-day workshop. We will cover things like the new private flood insurance rules and all the discussion around the compliance aid statement.  For example, When can you rely on it?, Where should it be located? What if it’s not there?, etc.


Get your team registered and join our team. Don’t forget to bring your questions. We will bring you Plain English translations, as well as, answer your questions along the way.


We’ll hope to see you there.


Register NOW!

Loan Exceptions & Fair Lending


Does your bank’s loan portfolio include pricing and/or underwriting exceptions? The answer’s probably yes, if you’re like most banks. Let’s look at Fair Lending and these exceptions.  It’s not that you can’t have exceptions. The key to it is really quite simple. They have to be monitored and they have to be controlled. To do that, you have to know where these exceptions are coming from, where they’re not coming from, as well as being consistent in applying those exceptions. In other words, we can’t have one lender in the bank, whose been there for 20 years, willing to make exceptions and then have a younger lender, that maybe just started in the last year or so, and they’re a by the book lender.


It’s a matter of chance when an applicant walks into the door as to how well they’re going to be able to negotiate with either the 20-year lender or the brand new lender. Is it really fair that the 20-year lender is more willing to go off the beaten path when it comes to negotiating on something that would maybe be a pricing or an underwriting exception? As opposed to the brand new lender who is only going to do it by the book because they’re afraid that if they don’t go by the book they might get in trouble. Now that doesn’t quite seem fair.


It’s not that you can’t have exceptions. The question is are they monitored and controlled? That’s the expectation that the industry and the regulatory agencies would be looking for when they come into your organization the next time. If you’re looking for more information on the risks that are at play when it comes to fair lending, how to mitigate them, the latest regulatory guides and expectations, again, I want to invite you and your team to join us for an upcoming two-hour presentation, All About Fair Lending. Get registered today for the latest plain English translation in that area.


Register Today!


Jerod Moyer


Closing Disclosure: Sales Price, Appraised or Estimated Property Value – Which One Is It?


Sales price, appraised property value, estimated property value – which one is it? That’s one of the many questions we get when we cover the closing disclosure requirements. We’re going to cover that in a little bit of detail here today. Let’s talk sales price first. What makes something sales price when we’re talking about TRID? In order to be able to use sales price, you have to have a loan that’s being secured with dirt that’s being purchased with those loan proceeds. Then it’s simple. Once we’ve figured out we have dirt that’s being purchased with the loan proceeds that are in front of us, then we look to the contract sales price. That is, in fact, the number that you will use for the sales price.


Appraised property value – we get a lot of questions on this. It’s somewhat of a gray area, so we’ve tried to make it more specific as we’ve moved forward. You may have heard us in prior years in a webinar give a little bit different answer but here’s where we stand today with the appraised property value. First, you have to have acknowledged that it’s not a purchase. In other words, there’s no dirt securing the loan that’s being purchased with these loan proceeds. That eliminates sales price. We’re then able to move onto “All right, do we have an appraised property value that we’re looking at?”, and this one’s pretty straight forward too.


Our take now is that if you are relying on a certified and licensed appraiser that has put together an appraisal, that’s what you’ll use for the appraised property value. If you’re going, “Well, we didn’t do a certified licensed appraiser or appraisal, we just did an evaluation.” Maybe internally, externally, but it’s just an evaluation. Then we would move on to estimated property value. The word that I would tie to this one is what are you planning or what did you use for underwriting? The same could be associated with the appraised property value too, but you’d want to use the appraised number from a certified licensed appraiser. So, it’s not the sales price. It’s not appraised property value. We go back to its estimated property value. What did you use for underwriting? That’s what gets disclosed.


I want to throw one more thing out here. TRID 2.0 brought another thing to the table that said, “When you’re using estimated property value, if there are any improvements that are going to be made yet not completed to the property that secures your loan, and you’re going to use the value of those improvements that are yet to be made when you do your underwriting, you have to include the value of improvements in the estimated property value.”


This is just one of the many things that we’re going to be covering in the upcoming webinar, TRID: How to Complete the Closing Disclosure. Line by line, our team walks your team through in a plain English translation of how to complete the closing disclosure. Get registered today to reserve your seat. Thanks.


Register Now!


Jerod Moyer