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Determining Training Frequency: Four Steps to Success

Lori Peterson, Director, Regulatory Infrastructure, CRCM

Nov 07, 2017

Deciding how often to provide training can be a challenge for even the most seasoned risk and compliance veteran. As with many compliance-related questions, the answer is “it depends”. But depending on what? Given there are hundreds of compliance requirements with thousands of discrete task-level knowledge points, how can you begin to establish an appropriate training regimen? A simple four-step process can help you take a more logical approach to planning your training calendar.

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Agile Regulatory Change Management is a Necessity

Lori Peterson, Director, Regulatory Infrastructure, CRCM

Oct 31, 2017

“Agile” in the software development industry refers to a software building process that relies on a series of short development cycles called “sprints” to prototype, test and release new software in faster, more efficient ways. Although “agile” is not a word heard often when referring to financial institution operations, being quick and flexible is essential to success in today’s business environment, particularly when implementing regulatory changes.

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Catch Me if you Can Part 2: Home Improvement

Sarah Boisvert, Lead HMDA Auditor

Oct 31, 2017

Earlier this year, I wrote about how to pin down one of the more difficult-to-define HMDA categories: refinancing. Read more about the common pitfalls in ensuring all refinancings are reported in the first part of this series. Today, I want to look at another category where reportable loans can slip through the cracks: home improvement.

Note: This discussion applies to institutions compiling their 2017 LAR under the current HMDA rule. The Home Improvement definition is changing on January 1st, 2018, along with many other aspects of Reg C. The implications of these changes will be the topic of a future post.

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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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