Blog
Does “Guidance” mean “Required”?

Donna Cameron, Director of Regulatory I/O, CRCM, CCBCO

Sep 12, 2017

With the increase in volume and complexity of new and revised regulations, we have seen a corresponding uptick in the number of “guidance” documents issued by the regulatory agencies.

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Should credit unions be free from the CFPB’s oversight and regulation?

Tiffany L. Brown, Esq., Regulatory Attorney

Sep 12, 2017

Before the inception of the CFPB in 2011, credit unions were regulated by the NCUA; however, Dodd-Frank granted the CFPB examination and enforcement authority over credit unions with assets over $10 billion, leaving the NCUA with oversight only over safety and soundness issues at institutions above that mark. In addition to examination and enforcement of large credit unions, credit unions are subject to a majority of the CFPB’s regulations. Should the CFPB end or in some way change the relationship it has with credit unions? Here is what the NCUA, CUNA, and the CFPB have to say on the matter. I’ve added my opinion as well - hopefully the perspectives of an attorney who has worked in both banks and credit unions, and now for a RegTech firm, may be of some value to the reader.

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HMDA Quality Edits and LAR Accuracy

Sarah Boisvert, Lead HMDA Auditor

Sep 05, 2017

The CFPB has released a Filing Instructions Guide (FIG) for HMDA data collected in 2017, in anticipation of data submission to the CFPB by March 1, 2018. The guide contains a detailed list of 2017 data edit specifications. Edits on the HMDA data are nothing new, however, by publishing their specifications in advance, the CFPB has allowed interested filers to see exactly how their data will be analyzed upon submission.

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Are You Ready to Report Open-End Credit?

Sarah Boisvert, Lead HMDA Auditor

Aug 17, 2017

Some of the biggest changes going into effect for HMDA in 2018 are the new rules for covered transactions. For the first time, reporting open-end lines of credit will be required. 

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Are there options for lenders when appraisers are in short supply?

Donna Cameron, Director of Regulatory I/O, CRCM, CCBCO

Aug 14, 2017

Nothing is more frustrating for a lender (and a borrower) than a delay in a loan closing due to a shortage of qualified real estate appraisers, which in turn means that appraisals need to be scheduled months rather than weeks in advance.

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Using Existing Flood Determinations

Brian Johnson, Director of Compliance Support, CRCM

Aug 09, 2017

The Regulatory Operations Center® (ROC) has already answered around 3,000 questions during the first half of this year. One of the most common questions asked is when, or if, a lender can use a previously obtained flood determination. This question might seem complicated on the surface; however, it's quite simple.

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Why do I need a Monitoring Program?

Lori Peterson, Director, Regulatory Infrastructure, CRCM

Jul 31, 2017

You might be asking yourself this question, particularly if your institution is smaller. If you have a history of satisfactory compliance examinations across products/services that haven’t changed much, if at all, you may wonder whether the value of monitoring outweighs the time and effort it requires. But take a closer look at the Consumer Compliance Rating System (CC Rating System) that became effective 03/31/2017 and you will find that monitoring is an integral component of your institution’s Compliance Management System. Specifically, your monitoring efforts should be sufficient to identify areas of weakness and assess various compliance risks across the institution.

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RegTech Reaches Its Tipping Point

Pam Perdue, EVP, Chief Regulatory Officer

Jul 25, 2017

In his best-seller The Tipping Point, Malcolm Gladwell defined a tipping point as the moment when something previously perceived as rare, fringe or unpopular becomes an epidemic, or gets recognized by the mainstream and is dubbed “a thing.” As our Continuity crew assembled at the ABA’s National Regulatory Compliance Conference in June, our swag giveaway was something else that had reached its tipping point...the fidget spinner. This pop culture phenom kept our booth buzzing with visitors, and nearly every person stopped to hear more about our groundbreaking unified Compliance Management System, the industry’s first RegTech solution geared toward managing all aspects of an institution’s CMS.

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Credit Reporting Changes Are Here - Are You Ready?

Donna Cameron, Director of Regulatory I/O, CRCM, CCBCO

Jul 19, 2017

The three major consumer credit reporting agencies (TransUnion, Equifax, and Experian) have been under increased regulatory scrutiny for the last several years. The Consumer Financial Protection Bureau (CFPB) received more than 185,000 credit report inaccuracy complaints through February 2017.  The high complaint volumes triggered the CFPB to take a closer look,  which resulted in aggregate penalties totaling $8.5 million in 2017 (as well as $17.6 million in consumer restitution). In addition, the CFPB has raised the potential for changes to the Fair Credit Reporting Act with the goal of increasing reporting accuracy.

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Regulations Still Need Work Despite Improvement Efforts

Tiffany L. Brown, Esq., Regulatory Attorney

Jul 03, 2017

Even the most experienced bankers have difficulty interpreting the language of federal banking regulations because of the style in which the federal regulations are written. Despite there being several pieces of legislation aimed at ensuring federal regulations are written in plain language, the problem still persists.

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