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Community Bank Compliance

Latest Compliance News

  • CFPB Issues FAQs on TRID Rule

    Aug 02, 2019
    The Consumer Financial Protection Bureau published frequently asked questions and answers on compliance with the TILA-RESPA Integrated Disclosure Rule, or TRID.
  • CFPB Updates Reg Z Thresholds

    Aug 02, 2019
    The Consumer Financial Protection Bureau issued a final rule with its annual amendments to dollar amounts for several provisions in Regulation Z.
  • CFPB Extends Debt-Collection Comment Deadline

    Aug 02, 2019
    The Consumer Financial Protection Bureau extended by one month the comment deadline on its proposed rule to implement the Fair Debt Collection Practices Act.
  • CFPB Reopens Comment Period on HMDA Thresholds

    Aug 01, 2019
    The Consumer Financial Protection Bureau formally reopened the comment period on its advance notice of proposed rulemaking on the Home Mortgage Disclosure Act.

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Upcoming Events

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Sep
23
September 23 - September 26, 2019
September 26, 2019
Annual Current Issues/Certification Conference* - MN
Event Type: Seminar/Institutes
Leadership Development, Information Technology Certification, Executive C-Suite Training, Compliance Certification, Compliance, Certification, BSA Certification, Bank Security Certification, Auditing Certification, Auditing
Minneapolis, MN
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Sep
29
September 29 - October 04, 2019
October 04, 2019
Compliance Institute* - TN
Event Type: Seminar/Institutes
Executive C-Suite Training, Compliance Certification, Compliance
10 Century Blvd.
Nashville, TN

Question of the Week

  • QUESTION:If a bank originates a 2nd mtg for a property in a SFHA & the 1st lien holder does not have sufficient flood coverage for both liens & does not escrow for flood insurance, does the 2nd lien holder have to escrow for the additional insurance?

    ANSWER: 

    Under the agencies’ regulations, junior lien holders are not required to escrow for flood insurance if the borrower has obtained flood insurance for a closed-end second mortgage loan that meets the mandatory purchase requirement. Thus, the lender or its servicer must ensure that adequate flood insurance is in place. Question No. 36 of the July 2009 Interagency Questions and Answers Regarding Flood Insurance explains the requirements for junior lienholders. If adequate flood insurance is not obtained, the lender or servicer would need to escrow. However, the escrow requirements do not apply to a junior lien that is a home equity line of credit (HELOC). 

    Reference: Interagency Flood Insurance Regulation Update Webinar: Q&As, 2015, Q8