A Regulatory & Legislative Advisory for Compliance Professionals
Inside . . .
3 Warning on
4 Report on Medical
Debt Collection and
4 Ombudsman Report
3 GSEs Announce
Bank Secrecy Act
5 FDIC Implemented
6 OCC on Money
6 Updated BSA/AML
7 Clarity Sought on
7 Treasury Remarks
at Money Laundering
December 31: SCRA Notice Form Expiration
The latest version of HUD’s SCRA notice of mortgage foreclosure protections form
expired at the end of November. Because Congress on December 12 enacted a law
that for the next year retains the one-year protection for servicemembers that requires
court orders before a lender can take action on a default, the information in the
existing form is still correct. As in the past, when the HUD form “expired” due to lack of
OMB approval, bankers continued to use the existing form. However, bankers should
not change the form in any manner. On December 3, ABA filed a letter to HUD
requesting guidance. Check ABA’s SCRA Topics page for updates.
BANKERS URGED TO SUBMIT POST-EXAM SURVEYS
One of the top concerns among bank CEOs is inconsistent supervisory expectations
and treatment related to examination experience, regulatory interpretation and
enforcement, or supervisory guidance. To help address these concerns, ABA and the
state bankers associations developed the Regulatory Feedback Initiative.
Since 2011, bankers have submitted nearly 2,500 post-exam surveys covering safety
and soundness and compliance exams. The surveys provide an opportunity to submit
anonymous feedback; the results are aggregated and shared with the regulatory
agencies and with CEOs of participating banks on request.
ABA encourages bank and thrift CEOs or their designees to submit a survey for any
exams completed this year, provided they have not already submitted surveys.
Request a survey link.
CFPB PROPOSES NEW SERVICING RULE UPDATES
On November 20th, the Consumer Financial Protection Bureau released a nearly
500-page proposed rule that would amend the servicing rules that went into effect in
January 2014. Comments on the proposal are due by March 16, 2015. Some
aspects of the proposal incorporate changes and clarifications sought by ABA, while
others include revisions and additional consumer protections requested by consumer
groups. The volume and scope of the proposed amendments are significant and will
have compliance and operational impacts for ABA members.
Topics covered in the proposal include:
Successors in interest;