Compliance Huddle December 2017

Agenda Exams/Audits Findings HMDA Beneficial Ownership Enterprise Risk Management

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?

HMDA HMDA 2018 - 1003, GMI, and the new DI, how are other institutions handling it until the URLA is available for use in 2019? 2018 HMDA Changes. New CIP Rules - Getting Ready. Proactive Compliance Monitoring - How to effectively identify developing compliance risk. HMDA posters for lobby

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?

Enterprise Risk Management Are you being asked about Enterprise Risk Management (ERM) during exam?  Do you have a formal program?(other banks)  

Anything Else on Your Mind? Wire Transfers out of Credit Accounts.  How many institutions do this?  What does the agreement look like?  How do they keep it clear in disclosures whether or not you have to follow Reg. Z or Reg. E for billing rights?

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.