Effective Date: July 23, 2015 for the Reg. J and policy changes and for the policy changes related to the posting and debiting of check and ACH transactions to financial institutions’ accounts and December 5, 2014 for the policy revisions to the principles for establishing future posting procedures for same-day ACH service and services for [...]
Our most popular blog post of last year was about writing a knockout SAR narrative (you can find part one here and part two here). But when reviewing suspicious activity reports, we’ve noticed a large number of issues associated with those troublesome beasts known as continuing SARs. As such, it seems that a guide to [...]
Cybersecurity expert Jay Ranade We’ve all heard the high-profile names of retailers and financial institutions that were the victims of a data breach in the past year (looking at you, Target, Home Depot, eBay, Michaels, PF Chang’s, Goodwill, Michael’s, JPMorgan Chase, Neiman Marcus, and more). Clearly, cybersecurity is becoming a bigger issue every [...]
In an effort to defend prepaid product consumers, the Consumer Financial Protection Bureau is proposing what it sees as strong, new federal protections. The intent is to provide protections to consumers whether they are sending a payment, swiping a card, or scanning their smartphone. As comments are due 3/23/2015, let's take a closer look at [...]
Effective Date: November 3, 2014 Just as the world of popular medicine seems to evolve (and even contradict itself), so too is the world of regulatory compliance in a constant state of flux. Nowhere is that more evident than with mortgage rules, and the CFPB has released a new mechanism for curing point and fees [...]
With 2014 coming to a close, it's a good time to look back fondly on our five most popular posts on the AffirmX blog. New to the blog? We post blogs from our subject matter experts almost every week to help explain (in plain English) developments and insights into compliance topics. Here are our top five [...]
Winston Churchill once said, “To build may have to be the slow and laborious task of years. To destroy can be the thoughtless act of a single day.” Financial institutions can surely relate to that quote—compliance is certainly the slow and laborious task of years and then your examiner comes in and can, so it [...]
Originally published on CUInsight.com. I’ll admit it: I’m a sucker for a good sports movie. One of my favorites is Miracle, the 2004 movie starring Kurt Russell, who plays Herb Brooks, coach of the 1980 U.S. Olympic hockey squad, which (and I’ll try to avoid any spoilers here, but the movie’s title might have given [...]
They say there's an exception to every rule, and in the case of the Secure and Fair Enforcement for Mortgage Licensing Act, or SAFE Act, there are actually two major exceptions to keep in mind. When used properly, these exceptions can be a small institution’s best friend. On the other hand, improper compliance with SAFE [...]
In the CFPB’s recent release of its Compliance Bulletin and Policy Guidance: Mortgage Servicing Transfer, the agency has targeted the transfer of residential mortgage servicing because it often has an adverse impact on consumers. In fact, servicers that are engaged in significant servicing transfers will, in cases deemed appropriate by the CFPB, be required to [...]
