June Compliance Monthly Newsletter
FinCEN Temporarily Delays Beneficial Ownership Requirements for Rollovers & Automatic Renewals and Grants Relief for Premium Finance Cash Refunds FinCEN announced a temporarily suspension of the application of the beneficial ownership requirements for certificate of deposit rollovers and loans that renew automatically. The relief is retroactive to the May 11 compliance date and will
continue until August 9, 2018. During that time, FinCEN will re-evaluate the requirement to determine if more permanent relief is needed.
June AccumeView: Executive Cybersecurity Pulse Newsletter
In April, the Federal Financial Institutions Examination Council (FFIEC) published a joint statement on the potential role of cyber insurance in financial institutions’ risk management programs. It is important to note that the FFIEC pointed out that the statement does not contain any new regulatory expectations and, therefore, there is no requirement to purchase cyber insurance.Download
May Compliance Monthly Newsletter
Agencies Finalize Rule Raising CRE Appraisal Threshold The Federal Reserve, FDIC and the OCC approved a final rule raising the required appraisal thresholds for commercial real estate transactions from $250,000 to $500,000. This represents an increase from the original proposal, which called for the appraisal threshold to be raised to $400,000. Under the final rule, the threshold for loans secured by one-to-four family residential properties will remain at $250,000; however, residential construction loans secured by multiple one-to-four residential properties would be considered CRE transactions.Download
May AccumeView: Executive Cybersecurity Pulse Newsletter
In a recent survey, Nearly Half of IT Execs interviewed stated that they don’t rethink or retool their approach to security after an attack, almost ensuring another attack in the near future. A critical step in the remediation of a security incident is determining what elements require change so that the incident won’t repeat itself. A mature IT organization will ensure that this step is never skipped: immature organizations are destined to have history repeat itself.Download
April Compliance Monthly Newsletter
CFPB Adjusts Mortgage Servicing Rule for Borrowers Facing Bankruptcy
The CFPB issued a final rule to help mortgage servicers communicate with certain borrowers facing bankruptcy. The rule gives mortgage servicers more latitude in providing periodic statements to consumers entering or exiting bankruptcy, as required by the CFPB’s 2016 mortgage servicing rule. The rule will become effective April 19, 2018, along with other servicing rule amendments affecting consumers in bankruptcy and successors in interest that go into effect that day.
April AccumeView: Executive Cybersecurity Pulse Newsletter
A new type of malware has been discovered that has been hidden for years, which spreads across routers instead of servers and workstations. Researchers believe that this exceptionally complex program can only have been designed by a nation-state. In the security-world, controlling the router is the same as having the keys to the kingdom. Its primary purpose appears to be espionage: for now businesses should not worry, but we’ll be keeping tabs on it’s activity.Download
March Compliance Monthly Newsletter
FinCEN is updating the Suspicious Activity Report (SAR) filing format, which goes live in June 2018. Beginning with the new SAR filings, batch submissions will have to be made in an XML-based file, rather than in the current ASCII fixed-length delimited file format.Download
March AccumeView: Executive Cybersecurity Pulse Newsletter
ATM Jackpotting has finally hit the US. In previous briefings, we have highlighted attacks in Asia, South America, Africa and the EU. In all reported cases, the bad actors physically compromised the ATMs using specialized tools to inject malware into the device. This is a good reminder that physical security barriers such as locks only slow down determined attackers – the root cause needs to be addressed wherever possible.Download
February Compliance Monthly Newsletter
CFPB Finalized Changes and Postpones Prepaid Rule The CFPB finalized updates to its 2016 Prepaid Accounts Rule. The changes adjust requirements for resolving errors on unregistered accounts, provide greater flexibility for credit cards linked to digital wallets, and extend the effective date of the rule by one year to April 1, 2019. The CFPB also included other clarifications
and minor adjustments to the rule.
January Compliance Monthly Newsletter
SCRA Sunset Date for Mortgage Foreclosure
The President has signed into law the National Defense Authorization Act for Fiscal Year 2018, which extends for two years, until December 31, 2019, the “sunset” on the temporary change of “90 days” in §303(b) and (c) of the Servicemembers Civil Relief Act to “one year.” For another two years, servicemembers will remain entitled to the foreclosure protections for one year beyond the end of their active duty service. The current HUD-SCRA delinquency notice for past-due mortgage payments can be used past its December 31, 2017 expiration date.