BlogPosts By Category


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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No More Free Lunches... Or Rounds of Golf!Meal & Entertainment Expenses under the Tax Cuts & Jobs Act

2/21/2018

The provisions of the Tax Cuts and Jobs Act will impact every individual and business. One of the provisions that has not been widely publicized but will have significant  impact is the new rules related to meal and entertainment expenses

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Branch Operations: Dual Control vs. Dual Presence

2/8/2018

Most branch environments have higher-risk areas that require dual control to access.  This is mainly because the theft or misappropriation of the contents in these areas could result in the financial institution suffering a loss.  Increased regulatory scrutiny is often applied to such areas.

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2018 HMDA FAQ: CRA Public File and Branch Disclosures

1/22/2018

Questions regarding the impact of the new HMDA regulation have been top of mind for our clients. Specifically, many of you have asked how the regulation affects CRA public file and branch disclosures. 

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CFPB Announcement: New Asset Size Thresholds

1/10/2018

Just three business days before the new year, on December 27, 2017 the Consumer Financial Protection Bureau (CFPB) released the following asset size thresholds for year 2018.

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Regulatory Update: Servicemember Lending

1/4/2018

Recently, new regulatory updates have been enacted that impact servicemembers and financial institutions. Stephen MacBeth explains how the National Defense Authorization Act for FY 2018 signed into law by the President impacts servicemembers, while Sarah Oliver offers insight on the new and amended Q&As in the revised Interpretive Rule for implementing the Military Lending Act (MLA). 

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Avoid Fair Lending Risk! Track Pricing Exceptions

12/13/2017

The tracking and monitoring of pricing exceptions has long been an expectation of financial institution regulators. If you are not already tracking and monitoring these exceptions, you may want to consider implementing procedures to doing so.

 

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Storytelling Matters: Sharing Your CRA Efforts During Exams

12/6/2017

The single piece of CRA-related advice that we most often give our clients is to tell their story. We summarize some of the CRA issues common amongst our client banks, but later, we will share some of the more innovative and original ideas to have come from them.

 

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2018 HMDA Prep: Sample Sizes & Error Thresholds for Examiner Testing

11/16/2017

The guidelines detailed how HMDA Loan Application Register (LAR) data, collected beginning January 1, 2018 will be validated by examiners.  In this article, we elaborate upon two topics that should be of importance to compliance officers -- how the testing sample is selected and the specific thresholds for resubmission due to errors.

 

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Effective Now: New Third-Party Sender Registration Rule

11/3/2017

Attention all Originating Depository Financial Institutions (ODFI), the Third-Party Sender Registration Rule is now in effect. Janice Weisz, AAP, has provided key points to assist you through this registration process and make you aware of additional requirements to keep in mind once the initial registration process has been completed.  

 

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2018 HMDA Prep: Examiner Guidelines for Testing HMDA Data

10/31/2017

Jennifer Paradise, CRCM provides more information to help you in your HMDA Prep for 2018! The Federal Financial Institutions Examination Council (FFIEC) has issued HMDA Examiner Transaction Testing Guidelines for validating Home Mortgage Disclosure Act (HMDA) data collected in or after 2018. 

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Conference Prep: Don't Forget Networking Opportunities

10/26/2017

Seasoned conference pros know that every conference is an opportunity to network, whether you go to attend, exhibit, or both. Here are some networking tips to consider before, during, and after the conference.

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How to Help Your Customers Impacted by Hurricane Irma

9/14/2017

We have started getting questions from clients in affected areas about what assistance they should be providing customers in affected areas. What should you be doing to help your customers affected by Hurricane Irma? 

 

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Regulatory Tripwire! Home Equity Line of Credit Statement Format

9/7/2017

Although this topic is not new, it continues to surface from time to time. I want to share a reminder of the regulatory requirements for properly disclosing on the borrower's initial periodic statement for a Home Equity Line of Credit (HELOC) the account-opening (start-up) fees paid out of the first advance.

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Identifying Third-Party Sender Relationships

8/17/2017

In a previous FAQ for the new NACHA rule, I addressed common concerns about the upcoming Third-Party Sender Registration rule, which takes effect on September 29, 2017. A key component of this rule is being able to properly identify Third-Party Sender relationships before the registration period begins. 

Many times, while performing audits, it is determined that the financial institution has customers acting as a Third-Party Sender and don’t even know it.  To help make sure that you are not one of those institutions, here is some information that describes what a Third-Party Sender is and some guidance on how to identify a Third-Party Sender, so you won’t be caught off guard. 

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