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BSA Trends: Student Mules

If you are involved with BSA/AML compliance, you know that it will keep you on your toes! Bad guys are always looking for new ways to get around the rules!

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Flood Insurance: Insurable Value

As you probably already know, the flood rules have this quirky requirement that says you need to obtain flood insurance in an amount sufficient to cover the lesser of three things: 1) the principal balance of the loan (or loans if there are multiple properties secured by the property); 2) the “insurable value” of the property (this is a complicated topic); or, 3) the maximum insurance available under the National Flood Insurance Program ($250,000 for most residences and $500,000 for most non-dwelling properties).

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HMDA Data for Large Filers

When it comes HMDA banks that are not eligible for the partial exemption (aka large filers), there are a couple of things to keep in mind.

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What’s This Compliance Cruise All about?!

Are you ready to cruise into compliance with us in January 2020?!? Here’s the highly anticipated tentative agenda for our Compliance Cruise! If you’re interested in setting sail with us to warm islands and white sandy beaches while getting the latest in compliance training, check out our website or give our office a call to learn more about our first ever Compliance Cruise! Register today to reserve your seat! Seats are filling quickly!

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Regulation CC: Reasonable Cause

When it comes to delaying fund under Regulation CC, what exactly is meant by “reasonable cause”? The Regulation tells us that if you have the existence of facts that cause a well-grounded belief in the mind of a reasonable person, you can delay the availability of funds. That’s not exactly the most-clear definition in the world. If you look at the model forms it has examples like, “We received notice the check is being returned unpaid”, “We have confidential information”, ‘Check is drawn on account with repeated overdrafts”, “Unable to verify indorsement”, etc. But the Regulation also says that reasonable cause goes beyond model forms as you could have other things that you feel are a reasonable cause. It just gets a little tricky.

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Cruise into Compliance…with an agenda!

Are you ready to cruise into compliance with us in January 2020?!? Here’s the highly anticipated tentative agenda for our Compliance Cruise! If you’re interested in setting sail with us to warm islands and white sandy beaches while getting the latest in compliance training, check out our website or give our office a call to learn more about our first ever Compliance Cruise! Register today to reserve your seat! Seats are filling quickly!

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HMDA Demographic Information: Don’t Touch It!

What do you do if an applicant marks a subcategory, but not the main category, when they complete their demographic information? For example, say the applicant marks that they are Mexican (subcategory) but they do not mark that they are Hispanic (main category).

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