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Community Bank Compliance

Latest Compliance News

  • House Passes Flood Insurance Extension

    May 15, 2019
    The House passed legislation to extend the National Flood Insurance Program through Sept. 30.
  • CFPB Launches Reg Reviews with Overdraft Oversight

    May 14, 2019
    The Consumer Financial Protection Bureau published a notice on how it plans to periodically review regulations under the Regulatory Flexibility Act of 1980 and request public input.
  • CFPB Issues Proposed Rule on Debt Collection

    May 09, 2019
    The Consumer Financial Protection Bureau issued a notice of proposed rulemaking to implement the Fair Debt Collection Practices Act. Under its proposal, debt collectors would be restricted in how frequently, and the way in which they contact consumers. The proposal also provides additional information to consumers to help them identify debts and respond to collection attempts.
  • CFPB Issues TRID Factsheet on Assumption Transactions

    May 03, 2019
    The Consumer Financial Protection Bureau posted a TILA-RESPA Integrated Disclosure rule factsheet.

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Upcoming Events

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Jun
09
June 09 - June 14, 2019
June 14, 2019
Compliance Institute* - MN
Event Type: Seminar/Institutes
Executive C-Suite Training, Compliance Certification, Compliance
2800 American Boulevard West
Minneapolis, MN
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Aug
05
August 05 - August 07, 2019
August 07, 2019
BSA/AML Institute* - CO
Event Type: Seminar/Institutes
Executive C-Suite Training, Compliance, BSA Certification
Denver, CO

Question of the Week

  • QUESTION: Is the director of an affiliate bound by the extension of credit requirements of Regulation O?

    ANSWER:

    Regulation O states:

    Extensions of credit to a director of an affiliate of a bank are not subject to sections:

    • 215.4 “General Prohibitions”,
    • 215.6 “Prohibitions on knowingly receiving unauthorized extensions of credit”, and
    • 215.8 “Records of member banks”

    If, the director of the affiliate is excluded, by resolution of the board of directors or by the bylaws of the bank, from participation in major policy making functions of the bank, and the director does not actually participate in such functions.

    Reference: Regulation O: 12 CFR 215.2(d)(2).

     

  • QUESTION: For bank's providing statements electronically, is it sufficient to provide a link to the Regulation E error resolution notice on the bank's Internet Banking page?

    ANSWER:

    No, providing a link to the error resolution notices on the bank's Internet Banking page is not sufficient.  Section 1005.8(b) states that "For accounts to or from which electronic funds transfers can be made, a financial institution shall mail or deliver to the consumer, at least once each calendar year, an error resolution notice substantially similar to the model form set forth in Appendix A (Model Form A-3)...on or with each statement required by 12 CFR 1005.9(b)."  As such, a general link on an Internet Banking page would not satisfy the requirement to provide the notice on or with the periodic statement. 

    Reference: 12 CFR 1005.8(b).