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Beneficial Ownership

Your Customer Due Diligence Program – Time to Fill in the Gaps: Part Six The newest piece to your customer due diligence program. You should have things in full swing now as the deadline is just around the corner: May 11, 2018. Let’s dive right in to highlight the key …

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Financial Assessment Is Working

The following is the fourth part in a series published at NewViewAdvisors.com/commentary and has been reprinted with permission. Financial Assessment is still working. FHA’s new policy of requiring a financial assessment (FA) of the borrower’s ability to pay has cut tax and insurance defaults by nearly three quarters and serious …

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Standard Due Diligence – Part 5 in a Series

Your Customer Due Diligence Program – Time to Fill in the Gaps: Part Five So far in this series we’ve addressed customer due diligence policies and procedures and their importance, CIP, and the customer risk profile – all components of your customer due diligence program. Now, we’ll spend a brief …

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Avoiding Surprises

Servicing Quality Assurance and Quality Control Monitoring Systems can be Management’s Best Friend By Jim Shankle and Bill Tyner As loan servicers face competitive challenges and increased regulatory and investor scrutiny, management must rely on internal systems to provide ongoing feedback on critical servicing components. Establishing internal monitoring systems should …

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From the Om-Bobs-Man: 2020 Vision

The Conference of State Bank Supervisors (CSBS) propelled a new web page including a video overview highlighting major initiatives and ideals of VISION 2020. The web page and video are slick, but VISION 2020 was announced last May, when the CSBS Board approved this policy statement: “CSBS, the states and …

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Monthly State Regulatory Update: February 2018

Arizona Notary Fees – The Arizona Office of the Secretary of State adopted provisions relating to notary public fees. These provisions are effective on March 5, 2018 (R2-12-1102). Colorado Fair Debt Collection Practices Act – The state of Colorado modified its provisions concerning the continuation of regulations for collection agencies …

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Ask the Compliance Experts: February 2018

Question: I was hoping to get your opinion on this scenario.  A loan is denied, and an adverse action notice is generated, can we re-activated the same loan number under a new loan program? Answer: In a circumstance where a credit decision has been made and an adverse action communicated …

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Customer Identification Program Requirements – Your Customer Due Diligence Program – Part Three

Why write about Customer Identification Program (CIP) requirements? Honestly, not a lot has changed to this area for quite some time. Very true, indeed. However, it never hurts to address a few questions to ensure that no gaps may exist. And, with the upcoming beneficial ownership rule effective on May …

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