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SAFE ACT ANNUAL RENEWAL

Posted by jholzknecht on  November 1, 2011
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The Secure and Fair Enforcement for Mortgage Licensing Act (SAFE Act) mandates the registration of mortgage loan originators (MLOs). Section .103(b)(1)(i) of the SAFE Act regulations requires MLOs to renew their registration each year during the annual renewal period. The annual renewal period extends from November 1st to December 31st. The annual registration requirement does not apply to a registered MLO who completed his or her initial registration with the Registry less than 6 months

NEW FLOOD INSURANCE Qs AND As

Posted by jholzknecht on  October 25, 2011
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The Agencies are adopting two of the five questions and answers proposed in the 2009 Interagency Questions and Answers: one question and answer relating to insurable value (question and answer 9) and another question and answer relating to force placement of flood insurance (question and answer 61). The Agencies are also withdrawing one question and answer relating to insurable value and have reserved this question and answer for later use (question and answer 10). The

CFPB SUPERVISION AND EXAMINATION MANUAL

Posted by jholzknecht on  October 18, 2011
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Category: Dodd-Frank Act
On October 14, 2011 the Consumer Financial Protection Bureau (CFPB) published it’s Supervision and Examination Manual. The CFPB will begin it’s first examinations in the next few weeks. The publication of the manual is a big deal, but is it a big deal for your institution? Probably not. The CFPB only examines institutions with more than $10 billion in assets, that group includes a little over 100 banks nationwide. So, if you are in that

Current Events

Posted by jholzknecht on  October 13, 2011
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Category: Lending Compliance
I spent the past two days as part of the panel at the BankersonLine.com annual Lending Compliance Triage Conference in Louisville, KY. We had two long days of presentations and discussions. We had many banks with us at the meeting site, and many more participating remotely. Joining me on the panel were Mary Beth Guard, Andy Zavoina and John Burnett of Bankersonline.com, Carl Pry of Key Bank, Kathleen Blanchard of Key Compliance Services, and Lucy

BLURRED LINES BETWEEN CRA AND FAIR LENDING

Posted by jholzknecht on  September 28, 2011
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Category: CRA, Lending Compliance
The Department of Justice’s Civil Rights Division, with it’s beefed up staff and budget, is actively pursuing fair lending issues. Several recent cases are blurring the lines between the Community Reinvestment Act (CRA) and the Fair Housing and Equal Credit Opportunity Acts. The purpose of CRA is to encourage banks to meet the credit needs of their local communities. The level of encouragement has increased significantly over the years. The Department of Justice (DOJ) has
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