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2019 Compliance E-News

May 1, 2019
Regulatory Compliance E-News
Frequently Asked Question & Answer - The rules governing private flood insurance go into effect on July 1, 2019. Is it mandatory that our institution begin accepting private flood insurance policies?

April 16, 2019
Regulatory Compliance E-News
Frequently Asked Question & Answer - My institution wants to start offering online deposit account opening for consumer accounts. What are my disclosure obligations with respect to such a product offering?

April 1, 2019
Regulatory Compliance E-News
Frequently Asked Question & Answer - Generally our customers request a debit card when opening an account. However, there are times when a customer will request a debit card several months later after opening an account. In these instances, we are not providing the customer with the Electronic Fund Transfers Act Disclosure and Fee Schedule when issuing the debit card after account opening. Is this acceptable based on the Electronic Fund Transfers Act requirements?

March 15, 2019
Regulatory Compliance E-News
Frequently Asked Question & Answer - Are financial institutions required to incorporate human smuggling/trafficking into their Bank Secrecy Act (BSA) Training?

March 1, 2019
Regulatory Compliance E-News
Frequently Asked Question & Answer - If a commercial loan has several properties being used as collateral and the transaction is determined to be Home Mortgage Disclosure Act (HMDA) reportable, should the Total Units data field disclose the dwelling units of one specified property or of all the properties being used as collateral?

February 15, 2019
Regulatory Compliance E-News
Frequently Asked Question & Answer - For our Identity Theft Prevention Program, should Certificates of Deposits (CDs) be assessed as covered accounts under the red flag risk assessment requirements of Subpart J to Regulation V (Fair Credit Reporting)?

February 1, 2019
Regulatory Compliance E-News
Frequently Asked Question & Answer - Does the Qualifile risk score provided through FIS/eFunds need to be disclosed on the adverse action notice when denying a deposit account? Does the Qualifile score fall under the Fair Credit Reporting Act (FCRA) requirements?

January 15, 2019
Regulatory Compliance E-News
Frequently Asked Question & Answer - Based on the Financial Crimes Enforcement Network (FinCEN) guidance, what red flags should financial institutions consider with respect to monitoring cryptocurrency transaction activity in consumer accounts?

January 3, 2019
Regulatory Compliance E-News
Frequently Asked Question & Answer - For the Loan Purpose Home Mortgage Disclosure Act (HMDA) Loan Application Register (LAR) data point, how should lenders distinguish the refinancing purpose from the cash-out refinancing purpose?  If an investor considers a transaction to be a cash-out refinancing, would it also be considered a cash-out refinancing for HMDA purposes?

Contact Us
For additional information or if you have a question that you would like us to answer in an upcoming Regulatory Compliance E-News, contact Stephen King, JD, AMLP, Director of Regulatory Compliance Services, at 617-428-5448 or sking@wolfandco.comErica Torres, CRCM, Regulatory Compliance Principal, at 617-261-8121 or etorres@wolfandco.com, or Heather Johnson, CRCM, Regulatory Compliance Supervisor, at 617-428-5438 or hjohnson@wolfandco.com.

 

View the 2018 Compliance E-News.