Compliance Huddle January 2017

Recent Exams Does anyone currently have examiners on-site? Is there still a continuing increase in request information? What is the focus of the on-site? Has anyone just been through an exam or recently received their ROE? Has examiner “tone” changed from the last on-site? Are the reports giving credit where credit is due, or if there were concerns, are the reports written in such a way that the regulators are seemingly sympathetic or more demanding? What are some of the areas of focus?

MLA Three months in now What’s on your mind? How are you dealing with the changes? Any pitfalls/recommendations?

HMDA - 2017 Tests Asset-size Threshold: On December 31, 2016, had assets in excess of threshold posted in the Federal Register (and posted on the CFPB’s website). Location Test: On December 31, 2016, the bank had a home or branch office located in an MSA or MD Loan Activity Test: The bank originated one or more home purchase or refinances secured by a first lien on a 1-to-4 family dwelling. Federally Related Test: The bank is either federally insured or federally regulated or originated a first- lien secured by a one-to-four family that was insured, guaranteed or supplemented by a federal agency or was intended for sale to FNMA or FHLMC Loan Volume Threshold: In the past two years, the bank originated at least 25 home purchase loans (including refinancings of home purchase loans).

2018 Uniform Loan Threshold Beginning on January 1, 2018, the uniform loan volume threshold test for all institutions will be effective. In the last two years, the lender originated 25 covered closed-end mortgage loans OR at least 100 covered open-end lines of credit It’s important to note that this is different than the proposal which set the threshold at 25 closed-end loans and did not discuss open-end lines of credit.

2018 Tests Asset-size Threshold: On the preceding December 31, the bank had assets in excess of the asset-size threshold published in the Federal Register and Posted on the CFPB’s website Location Test: On the previous December 31, the bank had a home or branch office located in an MSA or MD. The CFPB clarifies that an ATM or other free-standing electronic terminal would not fall under the definition of “branch” for the location test Loan Activity Test: The bank originated one or more home purchase or refinance of a Home Purchase Loan secured by a first lien on a 1-to-4 family dwelling Federally Related Test: The bank is either federally insured or federally regulated or originated a first- lien secured by a one-to-four family that was insured, guaranteed or supplemented by a federal agency or was intended for sale to FNMA or FHLMC Loan Volume Threshold: In the past two years, the bank originated at least 25 Closed-End Mortgages or originated at least 100 Open-End Lines of Credit

Beneficial Owners Mandatory compliance 5/2018 Who has already began implementation?

Anything Else on Your Mind…

Questions? Thank you for your participation and input into the conversation! If you have any additional questions, contact Compliance Alliance at hotline@compliancealliance.com or 888-353-3933.