Since the beginning of this year, banks have been buried in new federal regulations. Every week has brought something new that a bank will have to put in place, often, it seems, with little warning.
Here is a partial list of recent regulatory changes:
- Regulation Z: Closed-end; Changes in coverage; Early TIL; Disclosure delivery; Disclosure timing; When you can close; When you can collect fees; HOEPA; Higher priced mortgage loans and documenting ability to repay; Mandatory escrow; Regular homes and manufactured housing; Open-end disclosures; 21-day timing of statements; 45-day timing for notification of changes; New appraisal coercion rules; New adverting rules; New commentary
- RESPA: GFE changes; HUD changes; Escrow changes; Account analysis
- BSA: Exemptions – rules relaxed; Guidance on 314(b) information sharing; MSB registration list
- Reg D: Changes in reserve requirements; Relaxation of the 3 transaction limit on checks payable to third parties
- Reg CC: Combining check processing districts; In November 2008, the Fed announced that it had altered its restructuring plan substantially to ultimately make the Cleveland office the single paper check processing and adjustments site, and the Atlanta office the single electronic check processing site for the Federal Reserve System.
- Servicemembers Civil Relief Act: The protection given to service members in terms of the amount of time they have to respond to a proceeding or foreclosure is extended from 90 days to 9 months after they leave military service. These changes are in effect through December 31, 2010.
- Flood: Final Revised Interagency Q & A
- Appraisals: 2008 code of conduct; Appraiser independence; Reg Z appraiser coercion – new rules
- FCRA: Accuracy of information reported to credit bureaus; FAQs on ID theft rules; Technical corrections; FTC “Red Flags Website”
- Proposed SAFE Act: A national registry of mortgage originators – fingerprint requirements
- FTC proposal to curb unfair and deceptive mortgage practices
- Federal Reserve proposal to change disclosure for closed-end mortgages and HELOCs
Conclusion
Each of these new or proposed regulations will affect different departments in your bank, and to comply, you may have to change processes, procedures, and checklists; train the appropriate personnel; and develop audit or process tracing techniques to make sure you are in compliance.
This task can be mammoth; you have a bank to run. One solution is to involve some outside experts that can help you make the changes, train the appropriate personnel, and then leave.
For more information about the new regulations, please visit <a target=”_blank” href=”http://www.younginc.com”>www.younginc.com</a>
Article Source:http://www.articlesbase.com/banking-articles/an-avalanche-of-new-compliance-regulations-1355162.html
October 21st, 2009
davidguide
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