Archive

COMPLIANCE ACADEMY

Last week bankers from seven states gathered in Lexington, KY for Compliance Resource’s Annual Compliance Academy. The program covered a full range of lending and deposit compliance and BSA/AML topics. The final revisions to Regulation B were covered in the school on the date they were published by the CFPB; that’s up-to-date content. In addition to the material presented by the faculty the participants learned from each other in case studies. They discovered that most […]

DEALING WITH THE FIDUCIARY RULE

By Sonja Kriegsmann, JD, Guest Author The Department of Labor (DOL) has issued its long awaited Fiduciary Rule. The Rule expands who is considered a fiduciary when giving retirement investment advice under the Employee Retirement Income Security Act (ERISA) and the Internal Revenue Code. Although a final rule was issued, the DOL has subsequently published several issuances that impact both when the Rule becomes effective and the content of the Rule itself. Here’s a timeline […]

TRUMP STOPS NEW REGULATIONS, OR NOT

On January 20, 2017, White House Chief of Staff Reince Priebus issued a memorandum (the “Priebus Memo”) to the heads of executive departments and agencies instructing them to stop the regulation issuing process for a period of time. OK. So what does the Priebus memo mean to Compliance Geeks? It is not completely clear at the moment, but time will tell. Does the Priebus Memo apply to bank regulations? The memo is directed to executive […]

TREASURY INDEX WEEKLY AND MONTHLY AVERAGES: WHERE DID THEY GO?

Many lenders use the Treasury Index, specifically the weekly and monthly averages, as an index for adjustable rate mortgages. The applicable index plus the internal margin set by the lender determines the interest rate that will be charged on an adjustable rate mortgage. Lenders have historically retrieved the Treasury Index weekly and monthly averages from the H.15 report (the Selected Interest Rates report published by the FRB). As of October 11, 2016, the Federal Reserve […]

CONSUMER COMPLIANCE RATING SYSTEM REVISIONS – WE’RE FROM THE GOVERNMENT AND WE’RE HERE TO HELP YOU!

On November 7th, the FFIEC finalized the issuance of its updated Interagency Consumer Compliance Rating System (“CCRS”).  The press release that accompanied the revision stated that the document was intended to “more fully align the rating system with the FFIEC agencies current risk-focused, tailored examination approaches” and that “the rating system’s adoption will represent no additional regulatory burden for financial institutions”.  Or does it? So, far so good as we’ve all long known, through various […]