The Lesson of Chris Sale

By: Dean Harrington In the 7th inning of game four of the World Series, baseball’s best offensive team found itself starved for runs. The vaunted Red Sox attack had scored a mere three runs in its previous 25 innings, managing just a single hit in the first 6 innings of Saturday’s match-up with the Dodgers. That’s when Red Sox ace pitcher Chris Sale threw his most devastating pitch, aimed squarely at his own teammates no less. The 6’6” Sale rose to his feet in the visitors’ dugout at famed … [Read more...]

Investment Properties Under HMDA

Article By: Gregg Oberg, Spillane Consulting Associates, Inc. It's that wonderful time in the quarter when we put our HMDA data on the LAR once again. Ah, scrub season, you keep us so busy with interesting questions.  While we obviously want to get EVERYTHING right in HMDA, erring on Primary Purpose may be the single most costly mistake you can make. Here's a few tips on how to avoid making a critical mistake.  What’s the Big Deal? Determining whether credit is extended for … [Read more...]

Understanding New HMDA Exemptions

Article by: Gregg Oberg, Spillane Consulting Associates, Inc. The CFPB has provided updated interpretations on HMDA following EGRRCPA. How are you going to implement them?  Background The regulatory reform bill signed into law in May 2018 created two new “partial exemptions” to HMDA reporting; one for open-end loans and one for closed-end loans. Briefly, if you originated less than 500 covered closed-end loans in each of the past two years, you are “partially” exempt from what we’ve come … [Read more...]

Sharing Knowledge in New England

Article By: Gregg Oberg, Spillane Consulting Associates, Inc. One of the great things about SCA is the range of issues we get to see, and the wealth of knowledge we get to tap into while working with dozens of clients on a monthly basis. Today, we'll share some Systems knowledge courtesy of our own Paul Bates and Lance McGrath. What’s New, and What’s Next? We’ve been putting our ears to the ground this summer, out and about New England (and beyond) helping clients understand and solve the … [Read more...]

Using Quality Control to Prove Compliance

Article By: Gregg Oberg, Spillane Consulting Associates, Inc. Quality Control as a "Detective" Compliance Control I’ll skip the obligatory “compliance is hard and expensive” explanation; you’re already aware of that fact. The process—regardless of the regulation being complied with—begins with identifying and assessing risks. Policies, procedures and other controls are then implemented, and we hope we’ve met our obligations. But unless we continually monitor and test our programs, improving … [Read more...]

Are Small Banks Still Subject to HMDA?

Article By: Gregg Oberg, Spillane Consulting Associates, Inc. When regulatory requirements impact strategic or management action, our goal is to help business leaders make well-informed decisions. Change has come to HMDA once again; see how the S.B. 2155 Regulatory Reforms will impact your institution moving forward... S.B. 2155 and HMDA: A Simplified Explanation for “Small Banks” As you likely have seen, S.B. 2155 is now law. Let’s take a moment to applaud Congress for doing SOMETHING … [Read more...]

HMDA Reporting on Construction Loans

Article By: Gregg Oberg, Spillane Consulting Associates, Inc. When is Financing “Temporary?” Today I want to take a look at one of the least understood topics in HMDA—temporary financing exemptions. These exemptions most often come up in the context of construction loans (read: commercial loan dept); but the classic “bridge loan” scenario we often see on consumer residential transactions is also captured under the 12 C.F.R. 1003.3(c). Statutory Language The language of the “Temporary … [Read more...]

Who Ya Gonna Call?

Article By: Gregg Oberg, Spillane Consulting Associates, Inc. Compliance Support on Speed Dial SCA has established a Compliance Hotline to assist our clients with those one-off, unanticipated questions. Wondering if you need a LE and CD on an abnormal transaction? Not sure how to handle multiple properties as security in HMDA reporting? Just want a second set of eyes on an advertisement or new policy? These are all good reasons to call or email SCA’s Compliance Hotline. Not everyone has a team … [Read more...]

Building the BSA/AML Program

Article By: Gregg Oberg, Spillane Consulting Associates, Inc. When regulatory requirements impact strategic or management action, our goal is to help business leaders make well-informed decisions. Many of us are, at least in passing, familiar with the “Four Pillars” of an effective BSA/AML compliance program. But are we ready (or even aware) of the FIFTH Pillar; which becomes effective in May of this year? May 11, 2018 to be exact. If you're less familiar, or want a simple way to describe … [Read more...]

Vendor Management Best Practices

Article By: Gregg Oberg, Spillane Consulting Associates, Inc. When regulatory requirements impact strategic or management action, our goal is to help business leaders make well-informed decisions. Outsourcing a function DOES NOT outsource the corresponding Risk "Reliance on third-party relationships can significantly increase a bank's risk profile, notably strategic, reputation, compliance, and transaction risks. Increased risk most often arises from poor planning, oversight, and control on … [Read more...]