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Home Mortgage Disclosure Act

The Home Mortgage Disclosure Act was enacted in 1975, and codified as the Federal Reserve’s Regulation C – Home Mortgage Disclosure Act (HMDA). In July 2011, rule-writing authority for Regulation C was transferred to the Consumer Financial Protection Bureau (CFPB). The HMDA requirements are intended to provide the public with …

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Compliance Testing Plan – When?

Is annual compliance testing enough? Quarterly? What about areas that have experienced compliance problems in the past? Help! In a perfect world, Compliance Officers would have the time and staff to continuously test for all compliance requirements in a perpetual loop. Welcome to the real world, where time and staff …

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National Consumer Assistance Plan – Impact on Lending Decisions

By Jay Burns How is the mortgage industry handling the changes brought about by the new standards introduced by the three consumer reporting agencies Equifax, Experian, and TransUnion under their National Consumer Assistance Plan (NCAP) initiative? As of this writing, the new standards have been in place for less than …

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Gramm Leach Bliley Act

The Financial Services Modernization Act of 1999 is commonly known as the ‘Gramm Leach Bliley Act (GLBA)’ for the members of Congress instrumental in its creation. GLBA included requirements for privacy of consumer financial information, including disclosures about collecting, maintaining, sharing, and using the information, and security of the information. …

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Compliance Testing Plan – What?

The regulators expect it, industry consultants recommend it, and management wants it. What is “it?” Compliance testing. What, then, should be tested? In a nutshell, everything! Each financial institution is expected to maintain a Compliance Management System (CMS) to establish and meet its compliance responsibilities. The CFPB Supervision and Examination …

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UDAAP Risk is Risky Compliance Business

“How do you solve a problem like Maria? How do you catch a cloud and pin it down?” – Lyrics, “Maria,” The Sound of Music The singing nuns in the iconic film described the trainee Maria as “A flibbertijibbet! A will-o’-the wisp!” In financial services compliance, we have our own …

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