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Exception Tracking Spreadsheet (TicklerTrax™)
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Top Story Compliance Related

12/28/2017

NMLS seeks agenda items for Ombudsman meeting

An open meeting with the NMLS Ombudsman will be held Friday, February 9, 2018, from 8:30 a.m. to 11:30 a.m. CT, in conjunction with the 2018 NMLS Annual Conference and Training in New Orleans, Louisiana. Conference registration is not required to attend the meeting. Suggested agenda items regarding NMLS, state licensing, and/or federal registration are requested and will be accepted until January 17, 2018, via email to ombudsman@nmls.org. Individuals who submit discussion items must attend the meeting to present their issue. Please provide the issue and any relevant information on your company's letterhead. The meeting will be in-person only; there will be no dial-in available.

12/28/2017

OFAC amends ISISR

OFAC has announced amendments to the Iran Stabilization and Insurgency Sanctions Regulations to implement an Executive Order which ended immunities granted to the development fund for Iraq and certain other Iraqi property and interests in property. The amendments also implement certain technical and conforming changes. This amendment is effective upon today's publication in the Federal Register.

12/28/2017

Bureau announces HMDA tools additions

The CFPB circulated an email notice yesterday that it has launched a HMDA Check Digit Tool and Rate Spread Calcualtor, both available on the CFPB/FFIEC Resources for HMDA filers webpage.

12/27/2017

Two North Korean officials designated

OFAC has announced the designation and placing on the SDN list of the names of the Deputy Director and the First Vice Department Director of the Workers’ Party of Korea Military Industry Department (North Korea). See our OFAC Update for identifying information.

12/27/2017

FBAR deadline extended again

Because FinCEN has not yet finalized a Notice of Proposed Rulemaking issued on March 10, 2016, FinCEN has issued Notice 2017-1 further extending the filing date for FinCEN Form 114 - FBAR to April 15, 2019, for certain financial professionals with signature authority over foreign bank and financial accounts.

12/26/2017

Resource guide for partnering with MDIs

The FDIC has issued FIL- 64-2017 with ways insured depository institutions, including community banks, can partner with minority depository institutions (MDIs) to the benefit of all institutions involved, as well as the communities they serve. Highlights include:

  • Collaboration among MDIs or between MDIs and non-MDIs can provide viable options for sound and profitable lending and investments that meet the needs of underserved communities.
  • By collaborating with each other or with other community banks, MDIs may be able to enhance product and service offerings to unbanked and underbanked consumers located in low- to moderate-income geographies.
  • In many cases, institutions engaging in collaborative activities and partnerships with MDIs may receive Community Reinvestment Act (CRA) consideration for such activities.
  • Institutions interested in pursuing collaborative relationships with MDIs may contact the appropriate Regional Director or Regional MDI Coordinator for insight on possible collaboration opportunities with specific MDIs. Institutions may also pursue such collaborative opportunities directly.

12/26/2017

OFAC designations, removals and updates

OFAC has posted Transnational Criminal Organizations designations, designations removals, and designations updates, plus Kingpin Act designations updates. See our OFAC Update for details.

12/22/2017

Delay of Prepaid Accounts Rule likely

The CFPB has issued a statement on its Prepaid Accounts Rule, indicating that it "expects to issue a final rule amending certain aspects of its 2016 rule governing prepaid accounts soon after the new year. As part of that process, the Bureau expects, based on its review of the comments received, to further extend the effective date of the 2016 rule to allow additional time for implementation of the final rule. The Bureau proposed making changes to the prepaid rule in June; the comment period on the proposal ended in August."

12/22/2017

Agencies announce leniency on 2018 HMDA data

OCC Bulletin 2017-62, FDIC FIL-63-2017 and a public statement from the CFPB all state that the respective agencies do not intend to require data resubmission unless data errors are material or assess penalties with respect to errors for data collected in 2018 and reported in 2019 under HMDA and Regulation C.

The Bureau also announced it intends to open a rulemaking to reconsider various aspects of its 2015 HMDA rule, such as the institutional and transactional coverage tests and the rule’s discretionary data points.

12/22/2017

Agencies release annual CRA adjustments

The federal bank regulatory agencies have announced the annual adjustment to the asset-size thresholds used to define small bank, small savings association, intermediate small bank, and intermediate small savings association under the Community Reinvestment Act (CRA) regulations. As a result of the 2.11 percent increase in the CPI-W for the period ending in November 2017, the definitions of small and intermediate small institutions for CRA examinations will change, effective January 1, 2018, as follows:

  • "Small bank" or "small savings association" means an institution that, as of December 31 of either of the prior two calendar years, had assets of less than $1.252 billion.
  • "Intermediate small bank" or "intermediate small savings association" means a small institution with assets of at least $313 million as of December 31 of both of the prior two calendar years and less than $1.252 billion as of December 31 of either of the prior two calendar years.

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