The Four "Ms" of Enterprise Risk Assessments In Lewis Carroll’s 1865 novel, Alice’s Adventures in Wonderful, the following infamous exchange between Alice and the Cheshire Cat occurs: "Would you tell me, please, which way I ought to go from here?" "That depends a good deal on where you want to get to," said the Cat. [...]
“Qualified Mortgages”, Section 1026.43(e) Creditors are provided with a “safe harbor” from liability when they make loans that meet the definition of a “qualified mortgage”. A” qualified mortgage” is a mortgage other than a “higher priced mortgage” (subprime mortgage) as defined by Regulation Z that has been underwritten to meet the ability to repay requirements, [...]
Part 1 of a 2-part series. TRUTH IN LENDING ACT, REGULATION Z Effective January 10, 2014 The CFPB has issued a final rule to implement sections 1411 and 1412 of the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank Act), which requires creditors, like credit unions, to make a reasonable, good faith determination of [...]
Part 3 of a 3-part Series. In Part 1 of this series, we discussed how a sound understanding of the definition of enterprise risk is the first step in establishing a sound enterprise risk management program. In Part 2, we took a look at the three foundational corners of a sound ERM program. In Part 3, we take a [...]
Part 2 of a 3-part Series. In Part 1 of this series, we discussed how a sound understanding of the definition of enterprise risk is the first step in establishing a sound enterprise risk management program. In Part 2, we take a look at the foundational elements of necessary to build a sound ERM program. We have [...]
There are several compliance support tools on the market for community banks and credit unions to use. Some such tools are ComplyTrack, Continuity Control, and Compliance 360. These tools can be useful for organizing a financial institution around scheduled and regimented reviews of their bank’s or credit union’s compliance policies and the compliance readiness of [...]
Effective June 1, 2013 The Consumer Finance Protection Bureau (CFPB) recently issued a final rule designed to prevent mortgage lenders from steering consumers into higher cost and riskier mortgage loans. While most of the new rule does not take effect until January 2014, there are two sections embedded in the new rule that go into [...]
Final Rule Effective June 1, 2013 The Consumer Financial Protection Agency (CFPB) has issued a final rule to implement provisions of the Dodd-Frank Act to strengthen the rules that require escrow accounts be established for certain mortgage transactions. This new final rule lengthens the period of time from one year to five years that escrow [...]
First of a 3 part series. Risk. In today’s world, there is no escaping it. Not so long ago it was considered part of the fuzzy territory of doing business as a financial institution. Today, the principle of risk and risk management has become one of the hot topics for financial institutions and has given [...]
Notices Direct Notice to a Parent The FTC has reorganized and standardized the information for the direct notice requirement to identify the exact items of information that an operator must provide in each type of direct notice. In addition, each type of notice must provide a hyperlink to the operator’s online notice of information practices. [...]