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The most common HMDA questions that we receive are about how to properly  report multipurpose and multifamily properties. And it’s understandable… The 2018 modifications to HMDA were massive and many financial institutions are still dealing with the challenges of collecting data under the burdensome new requirements. Here’s a breakdown of how to properly report multifamily and multipurpose properties for HMDA Let’s start with ‘multifamily”. The construction method and total units, together, replaced property type reporting

HMDA Enforcement Actions in 2023… The 2018 modifications to HMDA were massive and many financial institutions are still dealing with the challenges of collecting data under the burdensome requirements. These changes continue to prove to be cumbersome and taxing. Program failures continue to plague financial institutions and in 2023, there were three very large enforcement actions for failing to file accurate data. Additionally, due to a lawsuit the CFPB had to rescind the 100 loan

Last week FinCEN held it’s annual Law Enforcement Awards Program ,which recognizes cases that have been successfully prosecuted using reports provided financial institutions, and emphasized how BSA reporting really does make a difference. The stories are always interesting but I think they also serve as a reminder to our teams that the work they do is important and has a real impact. And for many, this might be a much-needed reminder. Often, there is no

Yesterday, FinCEN announced a filing deadline extension for Beneficial Ownership Information for companies created or registered in 2024. Beginning January 1, 2024, reporting companies will be required to file information with FinCEN regarding their beneficial ownership. The rule requires new reporting companies, that is those created after January 1, 2024, to file their initial report within 30 calendar days of “receiving actual or public notice that the creation or registration of the reporting company is

On Tuesday November 21, 2023, FinCEN announced the largest settlement in U.S. Treasury Department History with virtual currency exchanger Binance Holdings Ltd. Binance, the largest virtual currency exchanger in the world, must pay approximately $4.3 billion in total to resolve violations of the Bank Secrecy Act (BSA), failing to register as a money transmitter, and sanctions violations. The settlement with FinCEN is part of a coordinated effort with OFAC, the U.S. Commodity Futures Trading Commission