Compliance Huddle November 2017

Agenda HMDA Beneficial Ownership Elder Abuse Mortgage Servicing Exams/Audits Findings

HMDA Specifically construction loans Does anyone have a HMDA record form prepared with all the new fields?

Beneficial Ownership How are other banks planning to notify customers of the Beneficial Ownership requirements? Does anyone have a vendor that is ready to capture Beneficial Ownership information? Are vendors ready for testing? CTR specifics

Elder Abuse Some states have specific requirements Fed requirements are listed in our policy 

Mortgage Servicing What’s on your mind?

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?

Anything Else on Your Mind? “I had a question regarding independent testing for BSA/AML compliance. The FFIEC BSA/AML manual says that it is recommended every 12 to 18 months. However, the FDIC manual regarding BSA examinations says that although it is not required by regulation it should be reviewed at least annually. Do you know of any FDIC regulated institutions that conduct their independent test every 18 months?” We are a half a billion $ bank with five offices, and we have only two full time compliance employees with a firm that does auditing for us. Is our situation unusual, or are there others having as hard a time as we are trying to get things done?

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.