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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

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,

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

On February 2, 2018 the Consumer Financial Protection Bureau (CFPB) updated its Resources for HMDA Filers page by adding a 2018 LAR Formatting Tool, and making minor updates to the 2018 Filing Instructions. The 2018 LAR Formatting Tool is designed to assist financial institutions create an electronic file that can be submitted to the HMDA platform. It can be used to collect 2018 data that is to be reported in 2019. The CFPB also updated

In a recent wide-ranging memo to the staff of the Consumer Financial Protection Bureau (CFPB) Acting Director Mick Mulvaney clarified the status of the agency. “When I arrived at CFPB, I told folks that despite what they might have heard, I had no intention of shutting down the Bureau. Indeed, the law doesn’t allow that, and as members of the Executive Branch we are charged with faithfully executing the laws. So let’s be clear: the