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HMDA Income

Question:  If a commercial officer uses net income to underwrite the loan, should we report Net Income instead of Gross Income on the HMDA-LAR? Answer:  While the regulation specifies “gross” annual income, it goes on to say, that is relied on...

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NCUA – An Increased Compliance Focus?

We’ve been saying for years that there are certain Regulators that are much harder when it comes to compliance than others.  If you have ever experienced a change in regulators, you can probably attest to that fact!  While the end goal of the regulators is...

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Don’t Forget to Comment on HMDA!

On May 3rd, we alerted you to an Advance Notice of Proposed Rulemaking (ANPR) seeking comment on whether any changes should be made to existing HMDA data fields. The ANPR specifically requests comment on the following: 1. Whether changes should be made to…any new data...

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Pulling Credit Reports

One of the things our review team does when they go into a bank to do a review is ask for a listing of all credit reports pulled for a specific period of time.  What could they be looking for?  Well, the Fair Credit Reporting Act requires that you have a...

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Join us at our BSA Conference this Fall!

The Bank Secrecy Act is a regulation that never sleeps. It’s important that you never stop learning and improving your program to make sure you stay ahead of the curve. That's why we want to invite you to our upcoming BSA/AML conferences this Fall! We're going to be...

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Private Flood Insurance Procedures

Are the Private Flood Insurance requirements causing you headaches?  If so, we can help!  Check out the Private Flood Insurance Procedures (with checklist) available now as a Free Download on our website!  These are just a guide to get you started so feel...

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FCRA/FACTA: Proving Compliance

Question:  Since there are no record retention requirements and/or no signature requirement for several of the required FCRA & FACTA notices, how do we prove compliance to examiners?   Answer:  You will need to demonstrate your process for providing the applicable...

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Increasing Overdraft Fees

Say Management comes to you and wants to increase overdraft fees.  What needs to be done to stay in compliance?   First, as the compliance officer, you need to be excited that they came to you before and not after they implemented the change because that doesn’t...

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Military Lending Act Safe Harbor

As we conduct training across the country on the Military Lending Act (MLA), there seems to be this ongoing confusion about the Safe Harbor provided by the Act, specifically, what it is and how it works.   In a nutshell, the MLA was enacted to provide protections...

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Joint Statement on Risk-Focused BSA/AML Supervision

On July 22, 2019, the Financial Crimes Enforcement Network (FinCEN) issued a joint statement in a continuing effort to improve transparency with their risk-focused approach to Bank Secrecy Act (BSA)/anti-money laundering (AML) supervision. The risk-focused approach...

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