BlogPosts By Category


Elder Financial Exploitation by the Numbers

7/11/2019

With the dedicated Elder Abuse Prevention Month of June behind us, it is important to not rest on your laurels. Elder financial abuse and exploitation quadrupled from 2013 to 2017. See what financial institutions have reported and the steps they take to protect this vulnerable group.

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An Important Resource from the FDIC

7/2/2019

For those of us “Compliance Geeks,” the recent release of the FDIC’s June 2019 Consumer Compliance Supervisory Highlights publication is like getting the very first copy of the newest book on the Best Seller list. Check out what high-level consumer compliance activities passed examinations and those that fell short.

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NACHA Update: Return for Questionable Transaction Rule

6/24/2019

Staying in compliance can be challenging, but staying up to date doesn't have to be. Check out what NACHA rule just came into effect and how you can get assistance.

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Using HMDA Data to Identify Fair Lending Risk

4/12/2019

After you have had a chance to catch your breath from this whirlwind year of regulatory adjustments to the HMDA regulations, you may want to consider using the data to evaluate the potential for fair lending issues.  

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Learning from the CFPB's 2018 Fair Lending Report

3/1/2019

In December 2018, the Consumer Financial Protection Bureau (the ‘Bureau’) released its annual Fair Lending Report, covering its fair lending-related activities during 2017. The report includes a listing of the most common Equal Credit Opportunity Act (ECOA)/Regulation B violations, that may serve as a checklist for reviewing your own institutions’ processes.

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Acceptance of Private Flood InsuranceFrequently Asked Questions

2/18/2019

The long-awaited final rule regarding the acceptance of private flood insurance policies has been released. The rule, effective July 1, 2019, requires regulated lending institutions to accept policies that meet the statutory definition of “private flood insurance." We have received and answered several questions regarding the final rule and want to share these here with the assumption that other industry participants have the same questions.

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NCUA Priorities for 2019

2/8/2019

The National Credit Union Administration (NCUA) has outlined their primary areas of supervisory focus for 2019, in its Letter to Credit Unions. 

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The CFPB: New Year, New Leader

1/10/2019

Now that the holidays are officially over its time to settle back into real life. Some of us do this more optimistically than others. Perhaps it depends on what your challenges are ahead. One thing seems certain; Kathy Kraninger, the new head of the Consumer Financial Protection Bureau (CFPB) has her work cut out for her. 

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The Value of Mentoring: Reflections, Relationships and Rewards

11/29/2018

Whether officially or unofficially, we’ve all had someone provide us mentorship in our lives. A mentor is simply defined as, “An experienced and trusted advisor,” and a mentee is the one being advised. We are committed to preparing the future generations at Saltmarsh by strengthening their personal and professional development, community engagement, and firm knowledge. 

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CFPB Delivers Rulings on HMDA Relief

10/31/2018

On May 24, 2018, the Economic Growth, Regulatory Relief, and Consumer Protection Act (the Act) was signed into law.  Section 104 of the Act amended the Home Mortgage Disclosure Act (HMDA) by adding partial exemptions from the disclosure requirements for certain insured depository institutions and insured credit unions.

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NACHA Approves Three New ACH Rules

10/22/2018

NACHA recently announced three new rules to expand the capabilities of Same Day ACH for financial institutions and their customers.  To help our readers prepare, I have summarized each rule and provided effective dates. 

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Saltmarsh Hosts 13th Annual Community Bank Events in Tampa

10/3/2018

Our 13th Annual Community Bank Events in Tampa featured three unique sessions with subject matter experts who focused on topics relevant in today’s banking and financial landscapes.

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Branch Operations: Streamlining Safe Deposit Box Procedures

8/30/2018

Banks often use safe deposit boxes to hold contents that require dual-control.  Contracts and access cards issued for the safe deposit boxes typically list employees who have access to the box at the time the contract is issued. A common issue we see is that as employees are promoted, moved to different branches, retire, etc., the contract and access card become inaccurate. 

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FASB Clarifies Implementation Date of CECL for Community Banks and Credit Unions

8/2/2018

The Financial Accounting Standards Board (“FASB”) has approved an amendment to the transition guidance related to the implementation of the Current Expected Credit Losses accounting standard (“CECL”) for privately held banks and credit unions.

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Advisory Insights: Introducing the New Lease Standard

6/14/2018

During my years in the financial institution industry, we made every effort to classify any lease agreement we entered as an operating lease as opposed to a capital lease. Not only did we want to avoid recording an asset and its corresponding liability on the entity’s balance sheet, we also did not want to expend the effort of the requisite capital lease accounting afterwards. 

This is no longer necessary, thanks to the new lease standard, ASC 842. 

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Bad Examples Make Good LessonsLearning from Wells Fargo

6/6/2018

Welcome to a short case study on Wells Fargo’s (Wells) latest bungle in the land of consumer compliance.  Hopefully this short read will save your institution about a billion dollars, or the latest civil money penalty charged to Wells as the result of the two publicly cited issues.  You’re busy.  I know.  So allow me to break down the thirty-five page consent order filed April 20, 2018 by the Consumer Finical Protection Bureau (CFPB) against Wells.  

 

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HMDA Data Collection FAQ: Should You Start, Stop, or Continue?

5/17/2018

Many of our clients are asking the same questions, and rightly so given the number of HMDA related proposed and final rules, amended rules, charts, and guidance documents published since early 2015.  Below we share answers to the most common questions we receive related to the ‘new’ HMDA.

 

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CFPB Issues New Rule: A Light in the TRID Black Hole

5/9/2018

On April 26, 2018, the CFPB issued a final TILA RESPA rule that provides institutions more flexibility when changes occur between the time a closing disclosure is provided to borrowers and the consummation of the loan. The final rule will be effective June 1, 2018.

 

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The Bank Advisors Host Their First CFO Roundtables of 2018

5/8/2018

Our Bank Advisors held their first Community Bank CFO Roundtable meetings of the year across the region. Paul Allen led our meetings in Tampa and Orlando, while Bill Massey headed the meetings for Ft. Walton Beach and Dothan, AL. 

 

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Don't Fall Victim to Cyber Crime!Protect Your Personal Information

4/26/2018

You are driving to a meeting with a new prospective client.  Your boss calls and needs those reports for her meeting that starts in 10 minutes.  Whipping into the local coffee shop with free wi-fi, you can shoot those reports out, buy a round of lattes for the meeting and still make it on time.  Out comes the laptop as you find a small table in the corner, and you connect to the CoffeeShoppe_Guest wireless network. The New Email button is clicked, the reports are attached, you add the recipient and click Send.  

 But, did you just expose your personal information?  Will you be a victim of cyber crime?  The most frequent target for cyber criminals is personal information

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Your Financial Institution's Role in the Fight Against Human Trafficking

4/24/2018

Human trafficking is much more prevalent than we’d like to believe. With over 600 human trafficking cases reported in 2017, Florida ranked 3rd among all states for reports according to the National Human Trafficking Hotline.  What can you do to combat this crisis?

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Advisory Insights: Financial Institutions - Options for Syndicated Loans

3/15/2018

One benefit of performing reviews of accounting operations for our Financial Institution (FI) clients is the chance to review a specific function that while infrequent, is unique to that client.

One such review is that of syndicated loans. These allow FIs to take part in large loans that they would otherwise not be able to originate alone. During a recent review of syndicated loans, the question was raised concerning the proper way to amortize purchase premiums or accrete purchase discounts. 

 

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Leadership in Your CommunityHow to Choose the Right Organization

3/13/2018

As a young professional moving back home to Pensacola over a year ago, I've had the opportunity to start from scratch in building my community involvement. Thankfully, I've found the community to be welcoming and appreciative of young professionals wanting to get involved. In fact, I would take it further to say the community truly embraces new and young professionals trying to make their way. Below are the pieces of advice provided by others that impacted my choices in determining where and how to get involved. 

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What's New? CFPB Releases New Five Year Strategic Plan

3/8/2018

On February 12, 2018 the Consumer Financial Protection Bureau (CFPB) released its Strategic Plan for FY 2018-2022.  A lot has changed since the first five-year Strategic Plan for FY 2013-2017 was published.  

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Bank Regulation AlertHMDA Changes Force Update of CRA Public File Requirements

2/27/2018

Effective January 1, 2018 - The Community Reinvestment Act (CRA) was amended on November 20, 2017 by the Federal Deposit Insurance Corporation, the Federal Reserve and the Office of the Comptroller of the Currency. The joint agency final rule revises the definitions of “home mortgage loan” and “consumer loan” to more closely align to the new revisions of the Home Mortgage Disclosure Act (HMDA).  Both the HMDA and CRA revisions became effective January 1, 2018.

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Past Posts By Category

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