Posted by Anthony Demangone
While the proposed changes to Regulation Z have grabbed our attention, other compliance issues continue to come up. With that in mind, here are a few things that have happened recently that I wanted to mention. We'll get back to Reg Z tomorrow.
- Everyone continues to ask HUD to delay implementation of its RESPA rule, due to take affect January 1, 2010. RESPA keeps saying, thanks, but no thanks.
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The CFPA debate continues to rage on the Hill. The latest development? An amendment that would exempt credit unions under $1.5 billion in assets. Stay tuned.
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The Fed continues its check processing restructuring. Yesterday, the Fed issued a final rule to implement recent changes. In this notice, I saw something of note. The Fed gave us a heads up that they'll need to tinker with Reg CC's rules. I'm not sure what those changes will look like, but here's why they'll need the changes. Due to the consolidation of check processing centers, next year at some point...all checks will be considered local.
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OTS issued a CEO memorandum that does a great job of summarizing how the recently enacted HOEPA rules affect HMDA reporting. In short, OTS has amended their HMDA examination procedures, and this CEO memo addresses those changes. It is a concise, clear overview.
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FinCEN has released the latest issue of its SAR Activity Review, Trends, Tips and Issues. This document is a BSA goldmine. In this issue, there's an article on SAR completion tips from law enforcement and another on how to avoid errors in SAR filings.
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Also, we hear that FinCEN is planning to release its rule to put stored value cards under its BSA requirements in February.
There. That's more than enough for a Monday.
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