Mar 21

Mar 21 Board Confidentiality of Suspicious Activity Reports

In this video, Adam talks about SAR confidentiality and how it applies to the bank and its directors. He even talks about how FinCEN sent a warning to directors and their attorneys reminding them of confidentiality of SARs.

Mar 12
Mar 12 Rural & Underserved List and What It Applies To

Adam Witmer

Regulation Z, Regulatory Update

Each year, the CFPB releases a list of rural and underserved counties. The most recent list was just released by the CFPB and provides a few changes from prior years. While this list is definitely not the most exciting of lists, it does have an impact on community banks and credit unions in two main areas...

Mar 11

Mar 11 Fair Lending Overview

Adam Witmer

Fair Lending

In this video, Adam provides an overview of fair lending by discussing the protected classes of Reg B and FHA and talking about the three types of discrimination recognized by the courts.

Mar 9
Mar 9 CFPB Issues Final Mortgage Servicing Rules

Adam Witmer

Regulatory Update

Yesterday, the Consumer Financial Protection Bureau (CFPB) issued a final rule that will help mortgage servicers communicate with certain borrowers who are facing bankruptcy. This final rule gives mortgage servicers more flexibility in providing periodic statements to consumers who are entering or exiting bankruptcy.

Mar 7
Mar 7 Why We Need Flood Insurance

Adam Witmer

Flood

The last few weeks have felt like a tropical rainforest. We have had more rain than I can remember having in just a few weeks time and our area is starting to see the problems with this. For example, my father-in-law has a rental property I had to go to last week that was almost underwater. The rain was coming down so fast that it had nowhere to go. In fact, the furnace vents are under the floor of the house and...

Feb 22
Feb 22 2018 HMDA Getting It Right Guide

Adam Witmer

HMDA, Regulatory Update

The FFIEC has finally released an updated HMDA Getting It Right Guide. The FFIEC release the new guide today, which is the first revision of the guide since 2013. The new version has been completely revised to reflect the HMDA changes from the 2015 final rule as well as the 2017 amendments that went into effect on January 1, 2018.

Feb 19
Feb 19 Fair Lending Risk - Overt Evidence of Disparate Treatment

Adam Witmer

Fair Lending

Overt evidence of disparate treatment is the first type of discrimination recognized by the courts and probably the easiest one to identify in an organization. This type of discrimination is defined as when a lender openly discriminates on a prohibited basis. This means that a lender publicly makes a statement or publishes an advertisement that is a blatant statement of discrimination. A simple example of this would be if...

Feb 18
Feb 18 Assessing Fair Lending Risk

Adam Witmer

Fair Lending, Compliance Management

Fair lending is one of the hottest topics in regulatory compliance. As the dust has settled from TRID and the examiners haven’t quite focused their full efforts on the new HMDA rules, fair lending scrutiny is as intense as it ever has been. In fact, it always has been a hot topic and will always be one. One trend new trend that I have been seeing, however, is a demand for community banks and credit unions to conduct a fair lending risk assessment.

Feb 15
Feb 15 CFPB Request on Supervision Process

Adam Witmer

Regulatory Update

On February 14, 2018, the CFPB issued a request for information on their supervision process. In a statement, the CFBP stated that they are seeking comments and information from interested parties to assist in assessing the overall efficiency and effectiveness of its supervision program and whether any changes to the program would be appropriate. This is the fourth such requests by...

Feb 9
Feb 9 FinCEN Updates SAR Form

Adam Witmer

BSA, Regulatory Update

FinCEN recently announced that they will be revising the Suspicious Activity Report. The new version of the SAR will be available in June of 2018 and will include several changes. FinCEN is currently in the process of developing and testing the updated SAR and has released some mock-ups of the proposed SAR, though they say that the final SAR may be slightly different. This is the first round of updates to the SAR form since releasing the new electronic version of the form a few years back. While we saw changes to the...