Large Bank Compliance Huddle January 2018

Agenda HMDA 2018 Recent Exams Reg. CC changes Beneficial Ownership

HMDA 2018 Updated December 2017: Beginning January 1st, 2018, the HMDA Platform is available to submit HMDA data collected in 2017. The rate spread calculator and check digit tool are now available. A searchable HMDA Self Service Knowledge Portal containing the answers to frequently asked questions is now available.

HMDA 2018 Cont’d HMDA Platform Beginning on January 1st, 2018, the HMDA Platform allows financial institutions to upload HMDA files, perform validation on the data, review edits, submit HMDA data, and complete the HMDA filing process. Technology Preview The Technology Preview provides resources for financial institutions preparing their systems to file HMDA data with the CFPB. Filing Instructions Guide Separate Filing Instructions Guides (FIG) are now available for data collected in 2017 and 2018. For data collected in 2017 For data collected in or after 2018 For data collected in or before 2016, please visit the FFIEC website for data submission resources.

HMDA 2018 Cont’d Loan/Application Register (LAR) Formatting Tool The LAR Formatting Tool is intended to help financial institutions, typically those with small volumes of covered loans and applications, to create an electronic file that can be submitted to the HMDA Platform. File Format Verification Tool (FFVT) The File Format Verification Tool is provided for filers who wish to confirm that a LAR file is formatted in the required pipe delimited text file format, and meets certain formatting requirements specified in the Filing Instructions Guide. Section 3 of the HMDA Tools Instructions guide provides further information on using the FFVT. Rate Spread Calculator The rate spread calculator calculates rate spread on loans and applications with an action taken date on or after January 1st, 2018. Check Digit Tool The check digit tool generates a check digit for an entered LEI and Loan / Application ID, and validates that the check digit is calculated correctly on an entered ULI. HMDA Loan Scenarios The HMDA Loan Scenarios is provided as an illustrative aid to help HMDA filers prepare their loan/application register. HMDA Self Service Knowledge Portal The HMDA Self Service Knowledge Portal is a repository of common questions received via HMDA Help. You can search the growing knowledge base by typing your question or other key words.

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?

Reg. CC Changes The final amendments update Regulation CC to reflect the evolution of the nation's check collection system from one that is largely paper-based to one that is virtually all electronic. The amendments create a framework for electronic check collection and return and create new warranties for electronic checks, which will result in a consistent warranty chain regardless of the check's form. As with existing rules for paper checks, the parties may, by mutual agreement, vary the effect of the amendments' provisions as they apply to electronic checks and electronic returned checks. The final amendments also modify the expeditious-return and notice of nonpayment requirements to create incentives for electronic presentment and return. The amendments become effective July 1, 2018.

Beneficial Ownership What’s on your mind?

Anything else on your mind? Follow-up – Large bank huddles every other month or every month? Majority say every month – should we shorten the time?

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.