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CFPB Rescinds Statements on COVID-Related Relief
Effective April 1st, the CFPB rescinded several policy statements previously issued in response to the COVID-19 pandemic. It also rescinded a 2018 Bulletin on “Changes to Types of Supervisory Communications”. This bulletin is replaced by Bulletin 2021-01,...
Tailored BSA Training
Training is one of the most important aspects of your BSA/AML program. The Bank Secrecy Act requires you to conduct training for all personnel including your Board of Directors. The key to effective BSA training is to keep things fresh and interesting, as well as,...
FREE Deposit Compliance Q & A Forum
Do you have burning questions related to deposit compliance? Struggling with Electronic Funds Transfers, Truth in Savings Act, Regulation CC deposit delays, etc.? If so, we’d love to have you join us on May 6, 2021, for our FREE Deposit Compliance Q &...
TRID Changed Circumstances
It’s normal for changes to occur during the loan process. If the loan is subject to TRID, however, you have to be careful. Knowing whether you have a valid changed circumstance is very important and it dictates whether you can reset tolerances. Are...
Applicants for Joint Intent
A common area of confusion when it comes to the joint intent rules, is “who” is an applicant. Regulation B defines an “applicant” as any person who requests or who has received an extension of credit from a creditor, and includes any person who is or may become...
Compliance Conferences
Can you believe it’s already April? It’s a little crazy to think we are just a little over five months away from our Fall Compliance Conferences. We went 100% virtual last year due to the pandemic and had an outstanding response. Thank you! Based on...
HPML Baggage
Do you make high priced mortgage loans (HPMLs)? While that term seems to indicate they’re a bad thing, in reality they really aren’t. HPMLs just carry a little more baggage than other types of loans you may make. For instance, if you originate a first-lien HPML,...
BSA Compliance: Helpful Resources
Information to help with BSA compliance Complying with the Bank Secrecy Act is constantly evolving and changing. The bad guys always come up with new ways to lie, cheat and you are charged with the important task of mitigating risk, as well as detecting,...
Money Laundering/Terrorist Financing Red Flags
If you are in the BSA world, you’ve likely been seeing the acronym “ML/TF” quite a bit recently. If you’re not in the BSA world, ML/TF refers to “money laundering, terrorist financing”. This was a new term added to FinCEN’s BSA/AML Examination Manual to help guide...
TRID: Sales Price vs. Estimated Property Value vs. Appraised Property Value
Page one of the Closing Disclosure provides a lot of different information about a loan transaction. When it comes to the Closing Information section (top, left-hand side) there is a field where you are required to enter either the “Sales Price”, the “Estimated...