Archive

TRID AND THE END OF DAYLIGHT SAVING TIME

Daylight Saving Time (DT) ends on November 1, 2020 at 2:00 a.m. What does DT have to do with TRID? The TRID rules under Regulation Z require creditors to disclose the time zone applicable to its location when disclosing the date and time the interest rate lock and estimate of closing costs will expire on the loan estimate. As a result, financial institutions located in areas that observe DT need to remember to change the […]

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PROPOSED REGULATION Z CHANGES FOR LIBOR TRANSITION

On June 4, 2020 the Consumer Financial Protection Bureau (CFPB) published a 219 page proposal to amend Regulation Z to facilitate creditors’ transition away from using the London Interbank Offered Rate (LIBOR) as an index for variable-rate consumer credit products. The CFPB is proposing changes to: Certain open-end and closed-end provisions to provide examples of replacement indices for LIBOR indices that meet certain Regulation Z standards. Certain open-end provisions restricting index changes, requiring change-in-terms notices, […]

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OCC AND FDIC ENCOURAGE BANKS TO WORK WITH CUSTOMERS AFFECTED BY CORONAVIRUS

On Friday, March 13, 2020, the OCC issued OCC Bulletin 2020-15 and the FDIC issued FIL-17-2020 encouraging banks to take steps to meet the financial services needs of  customers affected by Coronavirus (COVID-19) related issues. Both agencies provide information on steps banks can take to assist customers and communities, way the Agencies will help reduce burden on banks, and note all efforts must be consistent with safe and sound banking practices and applicable laws. Notable […]

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PANDEMIC PLANNING

As the government fully gears up for testing for the Coronavirus, the number of reported cases will likely explode. That is when the panic will begin and the need for your Coronavirus Business Continuity Plan will be the greatest. The Federal Bank Regulatory agencies have not provided any recent guidance related to an appropriate response to a pandemic. Previous guidance from the agencies on this topic includes: Influenza Pandemic Preparedness: Interagency Advisory, OCC Bulletin 2006-12, […]

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FINCEN CLARIFIES CTR SOLE PROPRIETOR AND DBA REPORTING REQUIREMENTS

On February 10, 2020, the Financial Crimes Enforcement Network (FinCEN) issued ruling (FIN-2020-R001) on currency transaction reporting (CTR) requirements, FinCEN Form 112, involving sole proprietorships and legal entities operating under Doing Business As (DBA) names. The changes will be effective April 6, 2020, September 1 for E-Filing batch filers. This ruling replaces FIN-2006-R003 and FIN-2008-R001. For sole proprietorships the ruling states: Complete a single Part I “Person Involved in Transaction” section with the individual owner’s […]

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