Compliance Huddle june 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?

Agenda Exams/Audits Findings HMDA Regulation CC Amendment FFIEC CMS Guidance Redlining – CRA/Fair Lending (REMA) This and That Anything else on your mind

HMDA Continues to be the #1 Requested Topic of Discussion – Again this month Where is everyone with LOS preparations? Policies, procedures, training? Any other concerns?

Reg CC Amendment The presumption of alteration would shift the burden to the bank that warrants that an item has not been altered; this could be either the depository bank or the collecting bank.  A bank would be burdened by having to provide evidence that the item is accurately reflected in the substitute form or that the substitute item is derived from an original that had been altered and/or forged.  The rule would also state that the presumption of alteration shall cease if the original item is made available for inspection by the parties involved. Additionally, the proposal would clarify that presumptions do not limit the ability for a bank to make a claim against another bank for losses allegedly incurred form an item alleged to be altered.

FFIEC CMS Guidance Has anyone had a compliance exam under the requirements for the new report format? Has anyone actually received the new ROE in this format?

CRA Self assessments? Which department does the CRA reporting through the FFIEC tool live? Loan department, Compliance or the actual CRA Officer? More about the Expected Market Area and the Assessment Area, what exactly is the difference?

This and That Fiduciary Rule – any words of wisdom from this group of peers? Beneficial Ownership – lingering questions Fair Lending as it pertains to small business loans Audit timeframes – for a low risk bank what are good timeframes for audits to occur – annually, every 18 months?

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.