Quarterly Update Q4 2013

Upcoming Updates

The Edcomm Group Banker’s Academy is dedicated to training excellence and compliance in the field of financial services. Our team of legal experts and research consultants have come together to bring you the very latest in updated regulations and notices from the federal banking agencies, including the Federal Reserve Bank, Office of the Comptroller of the Currency, the Securities and Exchange Commission, the Consumer Financial Protection Bureau, the National Credit Union Administration, and other regulatory authorities.

What's New?

The CFPB’s 2014 Lending Regulations – The Consumer Financial Protection Bureau (CFPB) has issued new rules that take effect in January 2014 that will provide homeowners and consumers shopping for a home mortgage with greater protection and rights. These rules address the consumer’s ability to repay; what constitutes a qualified mortgage; the 2013 HOEPA rule; new regulations for mortgage loan origination and originators; ECOA valuations and higher-priced mortgage loan appraisals; escrowing; and Truth in Lending Act (TILA) and Real Estate Settlement Procedures Act (RESPA) servicing.

On Learning Link™, the following courses and topics have been updated:
- Focus on Compliance
  - Module 10, Topic 11 “Appraisals”
  - Module 15, Topic 1 “Focus on Truth in Lending; Topic 4 “Disclosures”; Topic 8 “Higher-Priced Loans”; Topic 10 “The higher Education Opportunity Act”; Topic 11 “Ability to Repay/Qualified Mortgage Rule” (new topic); Topic 12 “TILA Servicing Requirements” (new topic)
  - Module 16, Topic 16 “RESPA Servicing Requirements” (new topic)
Similar updates have been made to corresponding topics in the following courses:
- Focus on Compliance for Credit Unions
  - Module 32, Topic 1 “The SAFE Act” has also been updated
- Focus on Compliance for MSBs
- Focus on Compliance for Mortgage Lenders
  - Module 15, Topic 1 “The SAFE Act” has also been updated
- Achieving Commercial Lending Excellence
  - Unit 6, Module 1, Topic 7 “Truth in Lending Act”
- Achieving Consumer Lending Excellence, ACLE CU
  - Unit 6, Module 1, Topic 8 “Truth in Lending Act”
- Achieving Mortgage Lending Excellence, AMLE CU
  - Unit 5, Module 1, Topic 8 “Truth in Lending Act”
- Achieving Platform Excellence, APE CU
  - Unit 6, Module 1, Topic 11 “Truth in Lending Act”
  - On Banker’s Academy LMS™, the following courses and topics have been updated:
    - Fair Lending
      - Topic 7 “Appraisals”
Regulation Z: Truth in Lending Act
- Topic 1 “Truth in Lending Act”
- Topic 4 “Disclosures”
- Topic 8 “Higher-Priced Loans”
- Topic 10 “The Higher Education Opportunity Act”
- Topic 11 “Ability to Repay/Qualified Mortgage Rule” (new topic)
- Topic 12 “TILA Servicing Requirements” (new topic)
Real Estate Settlement Procedures Act
- Topic 4 “RESPA Servicing Requirements” (new topic)
Regulation M
- Topic 1 “Regulation M”
The SAFE Act
- Topic 1 “The SAFE Act”
Mortgage Lenders: Truth in Lending Act
- Topic 1, “Mortgage Lenders: Truth in Lending Act”
- Topic 4, “Mortgage Lenders: TILA Disclosures”
- Topic 5, “Ability to Repay/Qualified Mortgage Rule” (new topic)
- Topic 6, “TILA Servicing Requirements” (new topic)

CFPB Readiness Course! – To help financial institutions ready for the bevy of lending regulations that take effect in January 2014, Banker’s Academy has developed a course geared toward implementation and understanding of the seven mortgage rules: Ability to Repay/Qualified Mortgage; 2013 HOEPA Rule; Loan Origination; ECOA Valuations; TILA HPML Appraisals; Escrows; and TILA and RESPA Servicing.

This new, highly interactive, HTML 5-compatible course is currently on Banker’s Academy LMS™.

Increased Contribution Limits to IRAs for 2014 – The Internal Revenue Service (IRS) released the maximum contribution limits for traditional and Roth IRAs, which is the smaller of $5,500 ($6,500 for individuals over the age of 50) or an individual’s taxable compensation for the year. This is the same limit released for 2013.

On Learning Link™, the following courses have been updated:
- IRAs and IRAs for Credit Unions
  - Module 1, Topic 1 “Introduction to IRAs”
Achieving Banking Excellence
- Unit 3, Module 1, Topic 6 “IRAs”
Achieving Teller Excellence, ATE CU
- Unit 3, Module 1, Topic 6 “IRAs”
World of Banking
- Unit 2, Module 2, Topic 4 “IRAs”
Achieving Platform Excellence, APE CU
- Unit 3, Module 1, Topic 6 “IRAs”
Sales and Service, Sales and Service CU
- Module 5, Topic 6 “IRAs”
- On Banker’s Academy LMS™, the course “IRAs” topic 1 “Introduction to IRAs” has similarly been updated.

Adjusted Exemption Threshold under Regulation M for Consumer Leasing – The Board of Governors of the Federal Reserve System (Board) and the Consumer Financial Protection Bureau (CFPB) have published final rules adjusting the exemption threshold for consumer leasing to $53,500, effective January 1, 2014.

On Learning Link™, the course “Focus on Compliance,” Module 20, Topic 1 “Focus on Regulation M” has been updated.
On Banker’s Academy LMS™, the course “Regulation M” topic 1 “Regulation M” has been similarly updated.

Money Transmission Module for MSBs – New content has been added concerning money service businesses (MSBs) and money transmission. The new module in “Focus on Compliance for MSBs” and the new course on the Banker’s Academy LMS™ “MSBs: Money Transmitting” each including three topics – “Overview of Money Transmission,” “BSA/AML Compliance,” and “Features of Money Transmitters.” The content gives an overview of types of MSBs and the regulations surrounding their operation within the U.S.

On Learning Link™, the course “Focus on Compliance for MSBs” has been updated with a new module 7.
On Banker’s Academy LMS™, the course “MSBs: Money Transmitting” has been created.

Updates for UDAAP – Information concerning Section 5 of the FTC Act, Title X Definitions, subprime borrowers and products, and the Fair Debt Collection Practices Act (FDCPA) has been added to existing UDAAP content. Examples of UDAAPs have also been added.

On Learning Link™, the following courses have been updated to reflect this information:
- “Focus on Compliance,” Module 44, Topics 2, 3, and 4
- “Focus on Compliance for Credit Unions,” Module 19, Topics 2, 3, and 4
- On Banker’s Academy LMS™, the course “UDAAP” topic 2 “UDAAP Act,” topic 3 “Third Party Relationships,” and topic 4 “UDAAP Issues” has been similarly updated.

Looking Ahead

Take a look at regulatory changes and improvements manifesting in the next quarter!

CFPB Supervision of Nonbank Remittance Transfer Companies. The Consumer Financial Protection Bureau (CFPB) has proposed a rule concerning the supervision of large nonbank remittance transfer companies. The proposed rule will bring about 25 international money transfer providers responsible for more than 150 million transfer transactions each year under the authority and supervision of the CFPB.

2014 Rulemaking Agenda for the CFPB. The CFPB has released a list of pre-rules and proposed rules under consideration for the first half of the new year, including the Home Mortgage Disclosure Act (HMDA), annual privacy notices, debt collection practices, requirements for prepaid cards, and more. The full list of regulations concerned can be found here.

2014 Regulatory Review by the NCUA. The National Credit Union Administration (NCUA) has released a list of regulations that will come under review in 2014, including Bank Secrecy Act Compliance and Procedures for Debt Collection. Public commentary is due by August 4, 2014.

Proposed Amendment to Regulation A. The Securities and Exchange Commission (SEC) has proposed an amendment to Regulation A concerning issuer eligibility, content and filing, and ongoing reporting requirements. Comments on the rule will close on March 24, 2014, after which the SEC will issue a ruling.

Proposed Revisions to Regulation HH. The Federal Reserve Board is considering revising existing risk-management standards outlined in Regulation HH designated as systemically crucial by the Financial Stability Oversight Council (FSOC). Comments are due by March 31, 2014, after which the Federal Reserve Board will issue a ruling.