Archive

REQUIRED LOAN ORIGINATOR POLICIES AND PROCEDURES

Section 1026.36(j) states, ” A depository institution must establish and maintain written policies and procedures reasonably designed to ensure and monitor the compliance of the depository institution, its employees, its subsidiaries, and its subsidiaries’ employees with the requirements of paragraphs (d), (e), (f), and (g) of this section. These written policies and procedures must be appropriate to the nature, size, complexity, and scope of the mortgage lending activities of the depository institution and its subsidiaries.” […]

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 […]

INDIRECT AUTO FINANCING – FAIR LENDING CONCERNS

Recently the Consumer Financial Protection Bureau (CFPB) published a bulletin (CFPB Bulletin 2013-02) that provides guidance on compliance with the fair lending requirements of the Equal Credit Opportunity Act (ECOA) and Regulation B for indirect auto lenders. The bulletin addresses practices that permit dealers to increase consumer interest rates and to compensate dealers with a share of the increased interest revenues. This guidance applies to all indirect auto lenders, including both depository institutions and nonbank […]

COMPLIANCE MASTERS GROUP

Are you looking for help to keep up with all the regulatory changes? ┬áDo you wonder what other banks are doing to cope with the volume of new regulations? Compliance Resource, LLC is offering free preview sessions of their Compliance Masters Group (CMG)┬áthis Thursday, March 21st from 11:oo am (EDT) to noon, and again on Thursday April 4th from 11:00 am (EDT) to noon. The free one-hour preview sessions explain how the CMG works, previews […]