All in Compliance Management

CFPB Provides Snapshot of Mortgage Complaints

Adam Witmer
Regulatory Update, Compliance Management

At the end of January (1/29/29), the CFPB released their “Complaint snapshot: Mortgage” document.  This report takes a deep dive into the mortgage-related complaints received by the Bureau and also highlights some trends that they have observed. For those of you with large mortgage originations and portfolios (which is almost every financial institution), this information can be extremely valuable for two reasons.  First, this information can…

5 Tips for Leading an Annual Day of Compliance Training

5 Tips for Leading an Annual Day of Compliance Training

Adam Witmer
Compliance Management

In this Compliance Clip (video), Adam provides 5 tips for leading an annual day of compliance training. As many banks continue to have an annual day of training that includes at least some compliance training, it is important for compliance professionals to be able to effectively deliver the content of the training. The reality of this is that the deliver can be a challenge because staff often resist the training and push back a bit or even complain that it doesn’t apply to them. Therefore, it is essential that compliance training be delivered in the best way possible. Adam uses this video to provide 5 tips (and a bonus) that he uses when leading compliance training for all employees of a financial institution.

Also, if you are interested in having Adam speak at one of your future compliance training days, you can contact us at members@compliancecohort.com.

5 Tips for CRCM Test Prep

Adam Witmer
Compliance Management

The CRCM certification (Certified Regulatory Compliance Manager) is arguably the most well respected and highest certification a compliance profession can achieve.  And for good reason. In order for you to just qualify to take the CRCM, you must be a banking professional with at least six years as a compliance professional within the last ten years (three of which need to be within the last five years).  Alternatively, you can qualify with only three years of experience if you also have met two of several different requirement options. Furthermore, you must be a compliance professionals with “management” experience overseeing the “full range of compliance risk functions.”  

Interagency Statement on Sharing of BSA/AML Resources Among Financial Insittutions

Adam Witmer
Regulatory Update, BSA, Compliance Management

On October 3, 2018, the main federal regulators, along with FinCEN, released a statement regarding instances in which banks and credit unions may decide to enter into collaborative arrangements to share resources to manage their Bank Secrecy Act (BSA) and anti-money laundering (AML) obligations more efficiently and effectively.  While this guidance may not be beneficial for a majority of financial institutions, this may be beneficial for very small institutions with a low-risk profile and less-complex structures, or those institutions who are owned by the same organization.

Federal Reserve Webinar on Complaint Management

Adam Witmer
Compliance Management

On August 29, 2018, the Federal Reserve hosted a webinar regarding focused on the topic of complaint management titled “Complaints as a Supervisory and Risk Management Tool.”  In this webinar, the Federal Reserve provided an overview of their complaint investigation process and provided an overview of what they look for when investigating complaints.  While this webinar didn’t provide significantly new information, there were a few takeaways from this training, including some guidance on how to manage complaints on social media.

Compliance Considerations for CD Secured Loans

Adam Witmer
Compliance Management, BSA, Fair Lending, CRA, Regulation Z

Compliance requirements for CD secured loans are not typically a huge topic of discussion for compliance seminar speakers or article authors.  That said, one of our members suggested this topic (you know who you are!), and I think it is a great topic to write on from the perspective of CD secured loans, rather than just bringing up these loans when discussing applicable regulations (which is usually the way it happens). The truth is that most financial institutions (and regulators) just…

Excessive Obligations vs Insufficient Income

Adam Witmer
Adverse Action, Compliance Management, Regulation B

Over the years, I have seen many financial institutions struggle with the adverse action notice requirements under Regulation B, especially in regards to what denial reasons should be listed on the adverse action notice.  This is particularly true when an applicant is denied for a reason relating to income and the applicant’s debt-to-income (DTI) ratio as most adverse action notice vendors provide two similar, but different, options relating to income: excessive obligations in relation to income and insufficient income for the amount of credit requested.  

Compliance Management Systems

Compliance Management Systems

Adam Witmer
Compliance Management

Adam talks about the core elements needed in a compliance management system including board of director oversight and the sub-elements of a compliance program.  This video outlines the expectations of a CMS as outlined by the CFPB and other regulatory agencies.  A sister article to this video can be found here.

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