Compliance Crue: July 2011

Compliance Crue for July 2011, in which Heather Line, compliance guru, leads discussion on a large number of topics. Download documents related to the meeting here (choose the table row for 7/5/11; if you are taken to the general compliance page, click on the "Compliance Crue" link in the bottom right of the page):

Heather talks about these topics in this order.
Already-implemented compliance items:
  • FACTA Risk-based pricing notice
  • New Reg Z disclosure: when mortgage loans are sold or transferred to a new owner.
  • Change for Reg Z: part of Mortgage Disclosure Improvement Act. New type of disclosure for truth-in-lending statement form mortgage loans. Replaces payment stream with a new interest rate and payment summary table.
  • Regulation E: change to gift card rules and disclosures.
  • NCUA Signage change
  • Reg Z: interim rule on appraisal independence
  • Loan originator compensation rule
  • New temporary lobby sign disclosure to do with share insurance, related to non-interest bearing transaction accounts
Pending compliance items:
  • Reg Z: Exemption threshold is being raised from 25k to 50k
  • Regulation CC: next-day availability is being increased to $200 from $100
  • Regulation Q: this regulation is being eliminated
  • Reg B and Reg D: Equal Credit Opportunity Reporting act and Fair Credit Reporting changes. Adding credit score information on a pair of notices.
  • Changes to adverse action notice
  • SAFE Act
  • Criminal history reports
  • A plethora of final CARD Act clarifications
  • Clarification of Interim rules for Mortgage Disclosure Improvement Act
  • FinCEN revised CTR and SAR forms--make sure the date on the form you use is March 2011. Use is required after October 1.
  • New NCUA ad rules: when to use the NCUA logo or tag line
  • Heads up on Consumer Financial Protection Bureau: combine the HUD1 and truth in lending statement into one document.



Labels: CARD act, CFPB, Consumer Financial Protection Bureau, ECOA, Equal Credit Opportunity Act, FACTA, FinCEN, MDIA, Mortgage Disclosure Improvement Act, NCUA Rules, NCUA Signs, Regualtion B, Regulation CC, Regulation D, Regulation E, Regulation Q, Regulation Z, SAFE Act, SAR, Truth in Lending, Video