Archive

REPORT ON IMPACT OF 2017 CHANGES TO CREDIT REPORTS

On February 23, 2018 the Consumer Financial Protection Bureau (CFPB) published the February 2018 Quarterly Consumer Report Trends, entitled Public Records. The CFPB also published an article summarizing the significant conclusion of the report. The report concludes that the lack of public records information has had minimal effect on credit scores. Effective July 1, 2017 The three nationwide credit reporting companies—Equifax, Experian, and TransUnion – removed civic public records that did not meet stricter standards for […]

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HMDA GETTING IT RIGHT IS BACK

The Federal Financial Institutions Examination Council (FFIEC) has released an updated and expanded version of the publication A Guide to HMDA Reporting – Getting it Right (aka the HMDA bible). The publication had not been updated since 2013. The 327-page 2018 Guide is updated for the revisions to the Consumer Financial Protection Bureau’s (CFPB) Regulation C, which implements the Home Mortgage Disclosure Act (HMDA) that were effective January 1, 2018. The Guide includes the  revised […]

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FOLLOW-UP TO RECENT CMG MEETING

During one of our February 16, 2018 CMG meetings regarding Private Flood Insurance we received an interesting comment and an insightful question. Comment – The comment, submitted privately, stated, ” I just wanted to let you all know that I just finished my compliance exam and we had to write memos for the loan files explaining that have reviewed and determined that our customers with higher flood deductibles are able to afford them.” While I […]

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SAR CHANGES

The Financial Crimes Enforcement Network (FinCEN) announced changes to the Suspicious Activity Reports Electronic Data Fields on February 2, 2017. On January 26, 2018 FinCEN issued an Important Notice to E-Filers that announces an update to the Suspicious Activity Report (SAR). The 2018 announcement states, ” the FinCEN Suspicious Activity Report (SAR) available on the BSA E-Filing System will be updated to adhere to the changes defined in Federal Register notice posted on February 2nd, […]

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OTTING MISSTATEMENT

Last week Comptroller of the Currency Joseph M. Otting issued a statement after meeting with Mick Mulvaney, Acting Director of the Consumer Financial Protection Bureau. According to the news release (NR 2018-14) from the Office of the Comptroller of the Currency (OCC)  Comptroller Otting stated “Acting Director Mulvaney has helped reduce the burden on the banking system by delaying implementation of his agency’s Home Mortgage Disclosure Act rule, committing to reconsider its payday lending rule, and […]

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