During the last few years we have had the Secure Act 1.0 and Secure Act 2.0 and new regulations on RMDs and Inherited IRAs. Plus, we have a myriad of new exceptions to the 10% penalty.
One banker commented “Reg E hasn’t changed, so what’s to learn?” While the Reg itself and the commentary haven’t changed, interpretations of who is a financial institution, what is an error and who has to investigate those errors have.
Recorded on March 14, 2023
Regulation CC: Funds Availability (Deposits and Holds)
Nobody wants compliance mistakes but when they are tolerable and in moderation, you learn from them and that’s an improvement. Mistakes can be great when you learn from someone else’s because you don’t suffer the consequences.
Did you inherit the safe deposit area and then start wondering what liability might exist? Historically, this responsibility has been routinely passed from employee to employee with little attention given to existing procedures or documentation.
The 2018 modifications to HMDA were massive and many financial institutions are still dealing with the challenges of collecting data under the burdensome new requirements.
Do you ever feel at a loss for where to start in compliance research? Do you have an inkling the answer is out there somewhere, but you’d have better luck winning the lottery than finding the concise answer to that tough compliance question?