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COMPLIANCE REVIEW/AUDIT CONSIDERATIONS FOR 2014

Compliance audits for 2014 are not business as usual. We have all been inundated by the volume of changes. There is confusion regarding when examiners will be ready to begin compliance examinations for the new and revised requirements and how intense those examinations will be. The regulators have indicated that “… oversight of the new mortgage rules in the early months will be sensitive to the progress made by institutions that have been squarely focused […]

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WHAT IS AN EFFECTIVE DATE?

Whenever federal financial institution regulatory agencies issue new final regulations they include an effective date. We have all seen, “The rule is effective January 10, 2014” or “The rule is effective for applications received on or after January 10, 2014,” but what does that mean. Apparently the term “effective date” means different things to different people. For financial institution regulatory agencies the term “effective date” apparently refers to the date by which a financial institution […]

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REVISED COMPLIANCE BROCHURE AND BOOKLETS

On January 6, 2014 the Consumer Financial Protection Bureau (CFPB) published three revised consumer publications, including a consumer information brochure and two booklets required under the Real Estate Settlement Procedures Act (RESPA), Regulation X, the Truth in Lending Act (TILA), and Regulation Z. These publications are titled: (1)  What You Should Know About Home Equity Lines of Credit (HELOC Brochure); (2)  Consumer Handbook on Adjustable-Rate Mortgages (CHARM Booklet); and (3)  Shopping for Your Home Loan, […]

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JUNE 1, 2014 NATIONAL FLOOD INSURANCE PROGRAM CHANGES

Recently the Federal Emergency Management Agency (FEMA) published a summary of the changes to the National Flood Insurance Program that will be effective on June 1, 2014. The changes result from the Biggert-Waters Flood Insurance Reform Act of 2012. The summary provides an excellent overview of some of the fun that is ahead of us. A copy of the notice is available here.   Notice to Compliance Masters Group Members – The upcoming changes to […]

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CHANGE IN WAITING PERIOD FOR FLOOD INSURANCE

Effective October 1, 2013 the National Flood Insurance Program no longer allows an exception to the 30-day waiting period for policies that are required as a result of a lender determining that a loan on a building in a Special Flood Hazard Area that does not have flood insurance coverage should be protected by flood insurance. The only allowable exceptions to the 30-day waiting period are: A. The initial purchase of flood insurance coverage in […]

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