—No, they really are this time. The CFPB has released an updated small entity compliance guide on the TILA-RESPA Integrated Disclosure rule. As you may remember the Dodd-Frank Wall Street Reform and Consumer Protection Act directed the newly created CFPB to integrate the mortgage loan disclosures under TILA (Regulation Z) and RESPA (Regulation X) back in [...]
I've become a huge fan of a reality show called Restaurant Impossible. It features a host, Chef Robert Irvine, who visits a restaurant in some level of disarray and attempts to completely overhaul it in 48 hours. This overhaul is usually filled with tears and trauma. After all, some of these restaurant owners have worked [...]
Asking which is the most common compliance question is like asking which is the most popular ice cream flavor—kind of expected (it’s vanilla according to the International Dairy Foods Association). But rather than deal with the obvious, vanilla question of “How do I ensure a satisfactory rating on my next compliance examination?” I’ve categorized questions [...]
For anyone who has attempted to make a complicated recipe, you know that even the best-laid plans can go awry. This sounds a lot like regulatory compliance—financial institutions have all the rules laid out in front of them, but extenuating circumstances, accidents, or outright violations happen (when baking, you have to take into account your altitude [...]
The frontier of cybersecurity has been relatively ungoverned territory. But with so many data breaches occurring in the recent past, the National Institute of Standards and Technology (NIST) has stepped forward to in an attempt to bring some order to this lawless land. NIST has released a document titled “Framework for Improving Critical Infrastructure Cybersecurity.” [...]
There’s nothing more frustrating than believing, nay, knowing that you are an exempt from a requirement only to find out after reading the commentary that the regulation actually denotes the opposite. The feeling could be compared to that of walking up the stairs, expecting one more stair at the top, when suddenly, your foot falls [...]
For financial institutions, awash in a sea of regulations, compliance issues are inevitable. Less certain is the matter of deciding which issues to present to the Board of Directors and how to present them. This can put compliance officers in the position of finding the delicate balance between not wanting to alarm the board while [...]
That the compliance storm is raging is no secret. The waves of new and changing regulations are threatening even the big financial institutions, let alone the smaller ones. A recent study conducted by George Mason University's Mercatus Center found that compliance costs have increased for more than 90% of small institutions. How smaller financial institutions [...]
The Bank Secrecy Act. For many, just reading those words can create feelings of nausea—and with good reason, given the prevalence of huge fines or cease and desist orders for BSA failures lately. However, it is precisely during such times when institutions can ill afford to let down their guard. Comptroller of the Currency Thomas J. Curry put it this [...]
Effective Date: January 10, 2014 With all the new regulations effective as of January 10, it’s easy to feel a little lost. From periodic statements to loss mitigation procedures, it seems almost no regulation has been spared alteration. The very survival of your institution may rely on your ability to guide it through the complex [...]
