BlogPosts By Category

Common HMDA Errors to Check Before Filing


By now HMDA-reporting institutions are in one of two camps - the HMDA-LAR is already scrubbed and ready for submission or the HMDA-LAR is being scrubbed and with any luck, it will contain no errors and it will be ready just in time for the March 1st deadline. Here are a few common errors found during the scrubbing process...

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Previously Suspended HELOC Line Amounts: Don't Forget TILA


Many of us have seen rising property values in recent years, which is generally a good thing. However, this brings up a regulatory issue for creditors that suspended or reduced the limit on home equity lines of credit due to a significant decline in value resulting from the mortgage financial crisis that began in 2008...

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Mariana Sawh Adds Certified AML and Fraud Professional to Her Credentials


We are proud to announce that Mariana Sawh has officially been designated a Certified AML and Fraud Professional (CAFP) through the American Bankers Association. 

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Saltmarsh Bank Advisors Host Inaugural Bank Event in Nashville, TN


Our Bank Advisors proudly hosted their inaugural Community Bank Events in Nashville, Tennessee on November 5th. The events consisted of a Compliance Funnel and Executive Form designed to cover timely topics in strategic management, technology, and regulatory compliance. This year’s lineup included FinTech, private flood insurance, cybersecurity, and an industry update by the Tennessee Bankers Association.

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Credible Challenge: How Can You Prove It Happens?


A couple of years ago during my bank director training, I kept hearing an unfamiliar term - “Credible Challenge”. I left the training with a strong impression that boards are expected to demonstrate the ability to credibly challenge management on key decisions... but how can you prove it happens? 

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Saltmarsh Hosts 14th Annual Community Bank Events in Tampa


In conjunction with our 75th Anniversary celebration in Tampa, the Bank Advisors at Saltmarsh proudly hosted their 14th Annual Community Bank Events! Designed to cover the essential areas of regulatory compliance, IT, executive and strategic management, the series offers a comprehensive view of what is impacting community banks throughout the region. 

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NACHA Update: Providing Faster Funds Availability Rule


Effective September 20, 2019, the Faster Funds Availability Rule will provide faster funds availability for many ACH credits. This new Rule increases the speed of funds availability for certain Same Day ACH and next-day ACH credits. Read more about the steps you need to take and how you can get assistance.

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Elder Financial Exploitation by the Numbers


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


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


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


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


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


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


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


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


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


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


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


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


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


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


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


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?


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


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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