All tagged Public

CIP Requirements for Business Account Signers

Adam Witmer
BSA

CIP requirements for business account signers can be a confusing subject for some.  While it would seem natural to require CIP for anyone opening an account, that isn’t technically what the rules require, especially when it comes to business accounts.  Therefore, let’s take a deep dive into the CIP requirements and how they apply to business account signers.

New SCRA Notice

Adam Witmer
Regulatory Update

At the end of the first quarter of 2018, HUD posted a revised SCRA notice which is sent to all delinquent mortgage borrowers.  This revised notice is the one that must be delivered between the 32nd and 45th day after a loan goes into default. The recent revision was made to reflect the extended protection from foreclosure which was adopted as part of the National Defense Authorization Act of 2018.  

Cyber Insurance Requirements From the FFIEC

Adam Witmer
Regulatory Update

While this topic is not usually considered to be in the realm of “compliance,” we wanted to share with you a regulatory update that was just issued and applies to the IT department of each financial institution so that you can pass this information to the appropriate person in your organization. Yesterday, the FFIEC issued a statement on “Cyber Insurance and Its Potential Role in Risk Management Programs.”  This statement was...

How the New CDD/UBO FAQs Apply to Community Banks and Credit Unions

Adam Witmer
Regulatory Update, BSA

For several months now, there have been rumors about a new set of frequently asked questions (FAQs) from FinCEN regarding the new CDD/UBO rules which require compliance by May 11, 2018.  Well, the mysterious FAQs are finally here.  Earlier today, the Financial Crimes Enforcement Network (FinCEN) released a set of updated FAQs regarding the new BSA rules that will be effective on May 11, 2018.  These FAQs relate to the new customer due diligence requirements for ultimate beneficial owners on accounts for legal entity customers. 

New Mortgage Servicing Rules and FAQs

Adam Witmer
Regulatory Update

Earlier this month, the CFPB issued a final rule that amends certain parts of the 2016 mortgage servicing rules relating to periodic statements.  This rule revised the timing requirements for services that are transitioning between modified or unmodified periodic statements and coupon books when a consumer enters or exits bankruptcy.  In addition to these rules, the CFPB

The Revised Loan Estimate

Adam Witmer
TRID

While most seem to fully understand the rules regarding the disclosure of an initial Loan Estimate, many seem to have a more difficult time understanding when a revised loan estimate is required.  For example, I have heard the following questions asked many times:

Load More