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Compliance Huddle

Compliance Huddle. December 2017. Agenda. Exams/Audits Findings HMDA Beneficial Ownership Enterprise Risk Management. Recent Exams. Does anyone currently have examiners on-site? Is there still a continuing increase in request information? What is the focus of the on-site?

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Compliance Huddle

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  1. Compliance Huddle December 2017

  2. Agenda • Exams/Audits Findings • HMDA • Beneficial Ownership • Enterprise Risk Management

  3. Recent Exams • Does anyone currently have examiners on-site? • Is there still a continuing increase in request information? • What is the focus of the on-site? • Has anyone just been through an exam or recently received their ROE? • Has examiner “tone” changed from the last on-site? • Are the reports giving credit where credit is due, or if there were concerns, are the reports written in such a way that the regulators are seemingly sympathetic or more demanding? • What are some of the areas of focus?

  4. HMDA • HMDA 2018 - 1003, GMI, and the new DI, how are other institutions handling it until the URLA is available for use in 2019? • 2018 HMDA Changes. New CIP Rules - Getting Ready. Proactive Compliance Monitoring - How to effectively identify developing compliance risk. • HMDA posters for lobby

  5. Beneficial Ownership • How are other banks planning to notify customers of the Beneficial Ownership requirements? • Does anyone have a vendor that is ready to capture Beneficial Ownership information? • Are vendors ready for testing?

  6. Enterprise Risk Management • Are you being asked about Enterprise Risk Management (ERM) during exam? • Do you have a formal program?(other banks)

  7. Anything Else on Your Mind? Wire Transfers out of Credit Accounts.  • How many institutions do this?  • What does the agreement look like?  • How do they keep it clear in disclosures whether or not you have to follow Reg. Z or Reg. E for billing rights?

  8. Questions? Thank you for your participation and input into the conversation! If you have any additional questions, contact Compliance Alliance at hotline@compliancealliance.com or 888-353-3933.

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