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IMPACT OF THE ELECTION

Posted by afaust on  November 11, 2016
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Following this week’s election we all need to evaluate the impact on our lives, families, and our businesses. Change is definitely coming, but will not happen overnight. If you have a positive view of the future I hope your vision comes true. If you are fearful of the future I hope your fears are unfounded. We need to closely watch the actions of Congress and the White House over the next few years to judge

CFPB STANDS IN WAY OF SOLUTION TO HMDA REPORTING PROBLEM

Posted by jholzknecht on  November 7, 2016
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Category: FFIEC, HMDA, Regulation C
Collection of 2017 HMDA data begins in less than two months. The Consumer Financial Protection Bureau announced last summer in its 2017 Filing Instructions Guide (FIG) that beginning with the HMDA data collected in 2017, filers will submit their HMDA data to the Consumer Financial Protection Bureau (CFPB) using a web interface referred to as the HMDA Platform. The HMDA Platform has not been released. That puts the industry in the awkward position of collecting 2017

AGENCIES PROPOSE PRIVATE FLOOD INSURANCE RULES

Posted by jholzknecht on  November 2, 2016
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The Office of the Comptroller of the Currency (OCC), the Board of Governors of the Federal Reserve System (Board), the Federal Deposit Insurance Corporation (FDIC), the Farm Credit Administration (FCA), and the National Credit Union Administration (NCUA) have issued a new proposal to amend their regulations regarding loans in areas having special flood hazards to implement the private flood insurance provisions of the Biggert-Waters Flood Insurance Reform Act of 2012 (Biggert-Waters Act). The proposed rule

SET YOUR CLOCKS BACK AND CHECK YOUR TRID DISCLOSURES

Posted by rcooper on  October 26, 2016
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Correction 10/27/2016: This article, initially posted on Wednesday, October 26th, 2016, included the designation “Eastern” in the first two paragraphs. All references to the designation “Eastern” have been removed from these paragraphs. It’s that time of year again. Daylight Saving Time, or Daylight Time (DT), ends on November 6, 2016 at 2:00 a.m. If your financial institution is in an area that observes Daylight Savings Time, ensure the time zone designation is updated to reflect
On October 19, 2016 the final Servicing Rules published by the Consumer Financial Protection Bureau on August 6, 2016 were finally published in the Federal Register. The final rule clarifies, revises, or amends provisions regarding force-placed insurance notices, policies and procedures, early intervention, and loss mitigation requirements under Regulation X’s servicing provisions; and prompt crediting and periodic statement requirements under Regulation Z’s servicing provisions. The final rule also addresses proper compliance regarding certain servicing requirements
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