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Reg CC Look-back Post July 1 Changes
The July 1, 2020, effective date for the Regulation CC changes has come and gone. But, that doesn’t mean additional questions won’t continue to arise after you implement the changes
Mortgage Servicing
There’s a misconception out there that the mortgage servicing requirements are a “big bank” thing, and that’s not entirely true. While there is a large servicer element to these requirements, small servicers can’t just ignore them altogether. One area where small servicers don’t get an exemption from the requirements is information requests. When you have an information request, there are several timeframes you must abide by.
The Challenging Environment You’re Facing
Yesterday, we held the first session of our six-part webinar series on Compliance Management. We discussed the challenging environment you’re facing, how to meet that challenge, as well as, the role of the Board of Directors and Management. We have a lot more to cover and it’s not too late to join us!
Flood Insurance & Mobile Homes Clip from July Monthly Connection
This is back in 2000. I actually emailed what was FEMA had kind of a helpline and they basically explain, let me see if I can just attach this here. There. Must a mobile home be tied down? Was kind of the question. What is a permanent foundation? Because the definition of mobile home means that it’s off of its tires. It’s not on its case anymore. Now I’m going to use this wording. If it’s a mobile home that can roll down the road on tires, I’m going to call that an RV. And I know there’s a big difference here. I’m talking about let’s just say a mobile home that qualifies for flood insurance means that it’s off of the tires. It’s supported on some type of foundation. It’s most likely going to be hooked up to utilities and stuff like that. And that’s what this memo that I just put up there talks about.
OCC Risk Perspective
As it relates to compliance, risk is increasing, and the increase is driven by COVID-19. As banks encountered reduced operations, employees teleworking, and a rapidly changing customer service environment; they were also expected to support customers via the CARES Act, process high volumes of PPP applications quickly, and implement a variety of forbearance and deferred payment programs.
HMDA: Preapproval vs Prequalification
When it comes to HMDA, preapprovals and prequalifications are completely different animals. Your bank might use the terms interchangeably but it’s important you understand the difference so you don’t end up in hot water with your examiners! If you have a preapproval program, it’s a big deal because it’s something you are required to report on your HMDA-LAR.
Overdraft Compliance
What regulations come into play when you’re dealing with overdraft compliance? The Truth in Savings Act (Regulation DD) and The Electronic Funds Transfer Act (Regulation E), are the most obvious players but they aren’t all you need to consider. The Truth in Lending Act (Regulation Z), Equal Credit Opportunity Act (Regulation B) and a little thing called UDAAP (Unfair, Deceptive or Abusive Acts or Practices) all potentially have some skin in the game.
Proposed Flood Insurance Q & A
How about a little regulatory relief? Who wouldn’t go for that, right? Hi there, this is Jerod Moyer with Banker’s Compliance Consulting. Today’s relief comes in the form of flood insurance and the frequently asked questions. We currently have a set that’s out there. They recently proposed an updated version of that. Now, what’s that mean for all of us? Well, many of the Q&As will remain mostly unchanged. They’ve added some, and then they made some pretty big revisions to some others.
Hemp Flash Session Agenda
Now the agenda. What we are going to hope to accomplish today is to walk through, at a high level in about a half hour and talk through the difference between legalized marijuana and hemp. We’re going to talk through the guidance that’s available, where we have some concrete information and where you have to make your own program, so to speak. We’re going to go through the farm bill, and how that changed him in the last couple of years. And then also discuss how do you manage that risk. If you are participating in that aspect of the Ag world, you need to understand how it works so you can make sure you’re managing that risk appropriately. We’re going to discuss Enhanced Due Diligence because the guidance does say that a hemp producer is a high risk customer, so you need to manage them appropriately. And then we’re going to talk through some of the specific SAR expectations and red flags.
Appraisal Clip E-Sign
Let’s go beyond coverage. Let’s talk a little bit about e-sign, let’s get this out of the way right away. So today we’re going to talk about a disclosure that’s required to leave the bank and go to the customer, as well as a free copy of the appraisal. Those are the two reg B requirements. We’re also going to talk about reg Z and they have very much the same thing.