We had some credit unions ask us about reporting methods for

Posts from August 2017

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cheap Canada Goose The Financial Crimes Enforcement Network (FinCEN) uk canada goose recently issued revised Geographic Targeting Orders (GTO) to target shell companies buying luxury properties. title insurance companies are required to canada goose identify the natural persons behind shell companies used to pay for high end real estate. The August 22, 2017, revised cheap Canada Goose https://www.canadagoosepark.com GTO also has broadened the transaction categories to now include wire transfers. Any covered transaction made “without a bank loan or other similar form of external financing; and. at least in part, using currency or a cashier’s check, a certified check, a traveler’s check, a personal check, a business check, or a money order in any form, or a funds transfer” must be reported to FinCEN. cheap Canada Goose

Canada Goose sale In addition to the revised GTO, FinCEN released FIN 2017 A003 to provide financial institutions and the real estate industry with information on the money laundering risks associated with some real estate transactions. The guidance provides some red flag activity and case examples. Word on the street is that an interagency group of canada goose black friday sale federal banking regulators has started working on amending the Federal Financial Institutions Examination Council’s Bank Secrecy Act exam manual to account for the new customer due diligence rule issued by the Financial Crimes Enforcement Network last year. No details as yet on how in depth canada goose coats on sale the updated manual and standalone sections on the Customer Due Diligence Rule will address the extent to which financial institutions will Canada Goose Coats On Sale have to obtain and verify beneficial ownership data from existing clients or which of the rule provisions Canada Goose Online will be prioritized for enforcement. ETA Final Laugh. Canada Goose sale

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buy canada goose jacket cheap On Thursday, the CFPB published a final rule canada goose uk black friday amending the 2015 Home Mortgage Disclosure Act rule. This finalizes technical changes and amendments that the Bureau proposed back in April 2017 while also finalizing a July 2017 proposal to increase the reporting threshold for open end home equity Canada Goose Parka loans from 100 loans to 500 loans. The regulatory references to HMDA below are not to the current version of the rule, but the rule as amended in 2015 (and further amended by last week rule). buy canada goose jacket cheap

canada goose store Technical Amendments. First, here is a summary of a few of the key amendments to the HMDA rule. canada goose Canada Goose Outlet store

canada goose deals Counteroffers. Section 1003.4(a)(8)(i) requires credit unions to report the action taken on covered loans and applications. Comment canada goose coats 4(a)(8)(i) 9 explains how to report the action taken for a counteroffer where the applicant does not accept the counteroffer or fails to respond. The final buy canada goose jacket cheap rule amends comment 4(a)(8)(i) 9 to broaden the possible actions taken that canada goose clearance sale could be reported in these situations, adding the following: canada goose deals

Canada Goose online “If the applicant agrees Canada Goose sale to proceed with consideration of the [credit union counteroffer, the [credit union] reports the action taken as the disposition of the application based on the terms of the counteroffer. For example, assume a [credit union] makes a counteroffer, the applicant agrees to proceed with the terms of the counteroffer, and the [credit union] then makes a credit decision approving the application conditional on satisfying underwriting or creditworthiness conditions, and the applicant expressly withdraws before satisfying all underwriting or creditworthiness conditions and before the canada goose store institution denies the application or closes the file for incompleteness. Similarly, assume a [credit union] makes a counteroffer, the applicant agrees to proceed canada goose clearance with consideration of the counteroffer, and the [credit union] provides a conditional approval stating the conditions to be met to canada goose uk shop originate the counteroffer. The [credit union] reports the action taken on the application in accordance with comment 4(a)(8)(i) 13 regarding conditional approvals.” Canada Goose online

canada goose Temporary and Construction only loans. Section 1003.3 specifies which transactions are excluded from HMDA reporting. The Bureau finalized clarifying changes to comment 3(c)(3) 1 and to add new comment 3(c)(3) 2 to specify that a construction only loan or line of credit is considered temporary financing and excluded under 1003.3(c)(3) if the loan or line of credit is extended to a person exclusively to construct a dwelling for sale. Here the new comment: canada goose

Canada Goose Outlet “Loan or line of credit to construct a dwelling for sale. A construction only loan or line of credit is considered temporary financing and excluded under 1003.3(c)(3) if the loan or line of credit is extended to a person exclusively to construct a dwelling for sale. Section 1003.4(a)(3) requires credit unions to report the purpose of a covered loan or application. Categories include home purchase, home improvement, or refinancing, an “other” category, and a cashout refinancing category. The Bureau is adding new comment 4(a)(3) 6 to clarify that, for purchased covered loans where the origination took place before January 1, 2018, a credit union complies with 1003.4(a)(3) by reporting that the requirement is not applicable. Canada Goose Outlet

canada goose black friday sale There are many more technical amendments and NAFCU is still reviewing the final rule. In the coming weeks, we will publish a Final Regulation for members providing a summary of the changes as well as a consolidated regulatory text so stay tuned. canada goose black friday sale

Amended Open end Line of Credit Threshold.

Section 1003.2(g) contains an institutional coverage uk canada goose outlet test as one of five criteria for determining if a credit union is a “financial institution” subject to HMDA reporting. This is detailed in a past NAFCU Compliance Blog post, here some of the commentary explaining the test as originally adopted:

canada goose clearance sale “Originations. Whether an institution is a financial institution depends in part on whether the institution originated at least 25 closed end mortgage loans in each of the two preceding calendar years [January 1, 2017] or at least 100 open end lines of credit [January 1, 2018] in each of the two preceding calendar years. Comments 4(a) 2 through 4 discuss whether activities with respect to a particular closed end mortgage loan or open end line of credit constitute an origination for purposes of 1003.2(g).” canada goose clearance sale

canada goose coats on sale The Bureau is amending HMDA effective January 1, 2018, to increase the open end threshold from 100 to 500. However, this increase is only temporary effective January 1, 2020, the threshold will revert to 100 open end lines of credit. canada goose coats on sale

canada goose coats Reporting 2017 HMDA Data (and Beyond). We had some credit unions ask us about reporting methods for 2017 canada goose factory sale HMDA data. Currently, and in the past, the FFIEC has collected and processed HMDA data for the CFPB, OCC, FDIC and NCUA. Currently, for 2017 reporting of 2016 data, Appendix A still points credit unions to the FFIEC for reporting. canada goose coats

As we noted before, the CFPB is developing a web based submission tool which will be intaking and processing HMDA data on behalf of the agencies. See, 80 Fed. Reg. 66246. That tool cheap canada goose uk will be used for the submission of 2017 data in 2018. Beginning in 2018, Appendix A will direct reporting credit unions to use the CFPB website and it submission tool/HMDA platform, which should be ready in the 4th quarter of this year for testing.

canada goose clearance Some credit unions have asked if submissions by mail will still be an option. in Appendix A states “Ifyou elect to submit your data by regular mail, then use the following address: []” and provides the FRB address for mailing data. As of January 1, 2018, the submission instructions in Appendix A will no longer contain any instructions for submission via regular mail, only instructions for submission through the CFPB portal. canada goose clearance

Canada Goose Parka Beginning in 2019, Appendix A will be entirely removed and new section cheap canada goose 1003.5(a)(5) will direct reporting institutions to the instructions on submitting data which will live in a separate document on the Bureau website. The reporting in 2019 will be done under the new rule, meaning the inclusion of instructions for submitting the new data collected in 2018. However, the actual method of submission the CFPB canada goose uk outlet HMDA Platform will have already been used in 2018 while submitting 2017 data Canada Goose Parka.