September 10, 2014
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Contents:
Small Entity Compliance Guide
Farm Credit Push
Breach!
FHFA: Proposed Rule



BKD 2010





Celerit


Harland Clarke


ICBA Securities





Travelers



 
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Real Community Bank
Small Entity Compliance Guide 
The Consumer Financial Protection Bureau updated its Small Entity Compliance Guide for the TILA-RESPA Integrated Disclosure Rule and its Guide to the Loan Estimate and Closing Disclosure forms. These updated versions replace editions published earlier this year.

The CFPB also released a timeline to help institutions understand the timing requirements under the rule. This timeline illustrates the process and timing of disclosures for one specific real estate purchase transaction under the TILA-RESPA Integrated Disclosure rule that will become effective on Aug. 1, 2015. 
Farm Credit Push 
The Farm Credit Administration, regulator of the Farm Credit System, appears to be seeking to implement, without a formal rulemaking process, its long-sought rural community investments program aimed at allowing FCS lenders to make non-farm investments.

Last November, the FCA withdrew its proposed regulation adopted by the board in May 2008 and said all FCS investment pilot projects would come to an end within 12 months. However, the FCA has now published an "informational memorandum" that lays out a series of questions by which FCS lenders can request FCA approval of non-farm investment programs.   

The memorandum requests FCS's determination that the requesting association maintains sufficient capacity to manage investment risks, including reputation, and legal risk arising from the investments. The memorandum requires information on how the investment benefits rural communities, businesses or agriculture. It also requires information on how institutions determine whether the community or business is in a rural area and asks for a list of other non-FCS financial institutions that will participate.

Breach!
The Home Depot yesterday confirmed the massive breach of credit and debit card data at its U.S. and Canadian stores. The retailer said the breach extends back as far as April. Home Depot advised customers with possibly fraudulent charges to report suspicious transactions to the financial institution that issued their cards-noting that the retailer and card issuers are responsible for those charges.

ICBA offers an  online toolkit with resources community bankers can use to respond to security breaches and to defend against hacking. The toolkit includes an ICBA paper that helps community bankers address key issues in the aftermath of a breach and communicate with customers and the media.
Read More from Home Depot.
FHFA: Proposed Rule
The Federal Housing Finance Agency (FHFA) proposed a rule Tuesday that would revise the requirements for financial institutions to apply for and retain membership in one of the 12 Federal Home Loan Banks (FHLBs).  The proposed rule would revise FHFA's existing FHLB membership regulation to ensure that members maintain a commitment to housing finance and that only eligible entities can gain access to FHLB advances and the benefits of membership. 

One provision of the new rule would establish a new quantitative test requiring all members to hold one percent of their assets in home mortgage loans and to do so on an ongoing basis. Read more here .

In a 2011 comment letter on the FHFA's advanced notice of proposed rulemaking, ICBA raised concerns over the regulatory burden imposed by the proposal and urged the agency not to advance it.
Tuesday, September 16, 2014                                

Emerging Leader Education: Writing Effective Credit Memos & Loan Narratives
 
Wednesday, September 17, 2014                                

Auditing Social Media: Planning & Risk Control Matrices
 
Thursday, September 18, 2014                    Complimentary               

Building a Compliance Scorecard