Compliance Action, Volume 23, Number 6

*** From the Editor: Articles uploaded ***

Check back frequently and catch the new content as it is published! Once the issue is complete, the .pdf version will be available (and you will receive an email alert).

- Patti Joyner Blenden, Editor

Appraisal Considerations of the EGRRCPA

by Mollie Newsome Sudhoff, CRCM

The Economic Growth, Regulatory Relief, and Consumer Protection Act has been hailed by many as “relief” from certain onerous terms of the Dodd Frank Act. There are many new compliance changes to be implemented over the next few months.

Auditing the Expedited Funds Availability Act

by David McCrea, CRCM

Due to the complexity of the check hold requirements and limitations, the disclosure and processing requirements, and the fact that both commercial and consumer depositors are impacted, there is significant inherent risk associated with Reg CC. With the implementation of systemic and automated controls, you can significantly minimize your residual risk - but you can’t completely eliminate it.

Action Training
Identifying Financial Activity from Human Trafficking

In addition to its unimaginable human cost, human trafficking is shockingly estimated to be one of the most profitable and fastest growing domestic and international crimes in the world. The red flags included here will be very useful for your financial institution in spotting and reporting suspicious activity potentially related to one or more forms of human trafficking. What an incredible opportunity for each of us to be a part of a solution that will bring relief to so many people caught in unimaginable, tragic circumstances.

Compliance Calendar

In the Editor's Opinion
Regulatory Relief Limbo

by Patti Joyner Blenden

Although most of the provisions of S 2155 are technically effective immediately, the revised mandate may conflict with existing regulations.

Compliance Notes

• US Anti-Fraud Task Force

Compliance Q & A

• Successor in interest & exemption
• Attorney client privilege & correct closing disclosure
• Loan Estimates, Closing Disclosures & TRID
• Is a loan production office a branch if it is accepting loan payments?
• Reg CC, RDC & Deposit hold rules

VA Fiduciary Activities Rule

by Patti Joyner Blenden

The Department of Veterans Affairs amended its fiduciary program regulations on July 13, 2018 which govern the responsibilities and oversight of fiduciaries appointed to assist vulnerable VA beneficiaries who because of injury, disease, or age, are unable to manage their VA benefits.

EGRRCPA Extends Exam Cycle

by Patti Joyner Blenden

On August 23, 2018, the OCC, Board, and FDIC jointly issued interim final rules effective upon publication in the Federal Register and simultaneously requested public comment on rules to implement Section 210 of the Economic Growth, Regulatory Relief, and Consumer Protection Act.<

Compliance Online
HMDA & EGRRCPA

by Patti Joyner Blenden

Be sure to check out the HMDA resources the Bureau has updated to reflect the impact of EGRRCPA, S2155. Our next issue will focus heavily on the impact on low volume HMDA filers.