Archive

SAR- E-FILING SYSTEM CHANGES

As promised earlier this month on July 27th, 2018, FinCEN released the following changes to the BSA E-Filing System production environment: FinCEN posted the new discrete entry form version (v1.2) of the FinCEN Suspicious Activity Report (SAR) for download/submission; FinCEN began accepting batch files containing the new FinCEN SAR in the new FinCEN 2.0 XML schema format; FinCEN updated the FinCEN CTR XML batch schema to prohibit certain unwanted characters/formatting for all elements values in […]

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UDAP VIOLATIONS ON ADD-ON DEPOSIT ACCOUNT PRODUCTS

On July 26, 2018 the Federal Reserve Board issued a consent order against Community Trust Bank, Inc. of Pikeville, Kentucky, for unfair and deceptive practices, requiring the bank to pay approximately $4.75 million in restitution to approximately 11,000 consumers and make certain consumer compliance enhancements. The practices were in effect from 1997 to present. It appears that the bank violated section 5 of the Federal Trade Commission Act in its offering of deposit account add-on […]

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PROPOSED FEMA FLOOD REGULATIONS

On July 16, 2018 the Federal Emergency Management Agency (FEMA) proposed revisions to its flood regulations. FEMA proposes to amend parts 59, 61, and 62 of 44 CFR. These parts contain regulations implementing the NFIP. In addition, FEMA proposes to amend Appendices A(1) – A(3) of part 61, containing the three forms of the SFIP: The Dwelling Policy Form, the General Property Form, and the Residential Condominium Building Association Form. FEMA proposes this rulemaking for […]

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Distressed or Underserved Nonmetropolitan Middle-Income Geographies

 On June 25, the Board of Governors of the Federal Reserve Board, the Federal Deposit Insurance Corporation, and the Office of the Comptroller of the Currency (the agencies) announced the availability of the 2018 list of distressed or underserved nonmetropolitan middle-income geographies, where revitalization or stabilization activities are eligible to receive Community Reinvestment Act (CRA) consideration under the community development definition. The agencies apply a one-year lag period for geographies that were listed in 2017 […]

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ZILLOW?

Recently a member of our Compliance Masters Group inquired, “It looks like the CFPB has dropped their case with Zillow according to a statement by Zillow.  We had a lot of our lenders wanting to co-market with realtors on Zillow.  Now what?” Good question. What we do know – Zillow Group received a letter from the CFPB on June 22 stating that the CFPB “had completed its investigation, that it did not intend to take […]

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