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FinCEN Proposes Rule

Posted by jholzknecht on  August 5, 2014
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Category: AML, CIP, FinCEN
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On July 30, 2014, the United States Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued a Notice of Proposed Rulemaking (NPRM) that, if finalized, will amend the Bank Secrecy Act regulations to enhance customer due diligence (CDD) requirements imposed on financial institutions (i.e. banks, brokers and dealers in securities, mutual funds, and future commission merchants and introducing brokers in commodities).  In an effort to increase financial transparency and protect the financial system from
Recently we polled our Compliance Master Group members on the Ability-to-Repay/Qualified Mortgages rules. There were no huge surprises, but we got a lot of confirmation of what we expected to see: Most creditors use a mix of ATR/QM options; The Small Creditor QM is the most popular ATR/QM option; Adopting the ATR/QM rules was a challenge, but did not reduce loan volume for most creditors; and Most creditors have not yet adopted Appendix Q, but

HMDA PROPOSAL PUBLISHED

Posted by jholzknecht on  July 25, 2014
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On July 24, 2104 the Consumer Financial Protection Bureau (CFPB) published proposed rules to implement changes to the Home Mortgage Disclosure Act (HMDA). Some of the proposed changes are mandated by the Dodd-Frank Act, others are part of a CFPB effort to modernize and streamline regulations. Comments on the 572-page proposal are due on or before October 22, 2014. Coverage There had been speculation that coverage would be expanded to all mortgage lenders that originated
HOMEOWNERSHIP COUNSELING POLL Compliance Masters Group July 18, 2014   A recent poll of our Compliance Master Group members centered on the issue of homeownership counseling rules. There were no huge surprises. We got a lot of confirmation of what we expected to see: Providing the list of counseling organizations is not a significant burden; The potential burden on consumers is high, but unrealized, since most of our members have few, if any, transactions subject

CMG – THIRD ANNIVERSARY

Posted by jholzknecht on  July 15, 2014
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  Today is the third anniversary of the founding of the Compliance Master Group. Thanks to all of our members. You have made the CMG a success. We look forward to helping you build and maintain your compliance management systems for years to come.   Homepage
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