Financial Institutions

Wednesday, 12 December 2018

TRID Rules For Partial Payment Policies Effective October 1, 2018

Written by The Rehmann Team

Among the Reg Z changes that went into effect on October 1 is a new requirement for disclosing partial payment policies in mortgage transfer notices. If a bank has to provide a mortgage transfer notice under current Reg Z requirements, it must now include information about the partial payment policy when issuing the notice. The rule applies if the transfer is for a closed-end consumer credit transaction secured by a dwelling or real property, including but not limited to a mobile home or co-op unit. The rule does not apply to a transfer of a reverse mortgage...

Wednesday, 12 December 2018

Beware of Fileless Cyber Attacks

Written by The Rehmann Team

Most banks are familiar with cyber attacks that download viruses and other files onto networked computers, spreading their malicious activities throughout an organization. A new type of attack is rapidly emerging – non-malware or fileless attacks. These attacks gain control of computers by accessing trusted, but vulnerable, software applications and web browsers that are already installed on the computer which a typical employee uses every day. They also access operating system tools to gain privileges to carry out commands across a network and get a hold of confidential information...

Monday, 20 August 2018

SEC Amends Definition of SRCs

Written by The Rehmann Team

The Securities and Exchange Commission (SEC) approved several final rules and proposals at its June meeting, the last one before Commissioner Michael Piwowar’s departure. Specifically, the SEC amended the definition of a smaller reporting company (SRC) to allow more companies to provide scaled disclosures in SEC filings when “going public.” The intent is to promote capital formation and reduce compliance costs for smaller companies while maintaining investor protections. Under the new definition, which becomes effective September 20, 2018, a company will qualify for SRC status if it has: Public float of less than $250 million (the threshold was increased from $75 million)OR Annual revenues of less than $100 million as of the most recently completed fiscal year AND no public float or a public float of less than $700 million Public float is calculated by multiplying the number of the company’s common shares held by non-affiliates by the market price and, in the case of an IPO, adding to that number the product obtained by multiplying the common shares covered by the registration statement by their estimated public offering price...

Monday, 20 August 2018

Wire Fraud Continues To Plague Real Estate Industry

Written by The Rehmann Team

In June 2018, the U.S. Attorney General’s office announced that Federal law enforcement arrested 74 people in the U.S...

Monday, 20 August 2018

TILA/RESPA Integrated Disclosure (TRID) Changes Start October 1, 2018

Written by The Rehmann Team

The Consumer Financial Protection Bureau (CFPB) published a final rule closing the so called “black hole”—a timing issue regarding when a consumer receives a revised TRID Closing Disclosure. TRID requires estimated closing costs to be disclosed in good faith, meaning that the charge to the consumer does not exceed the amount originally disclosed on the Loan Estimate. However, some closing costs are disclosed in good faith if the charge paid by or imposed on the consumer is within a “tolerance” specified in the TILA-RESPA Rule. For example, the total of recording fees and other third-party charges cannot exceed the total of the amounts disclosed on the Loan Estimate by more than 10 percent...

Tuesday, 22 May 2018

Proposed Changes to CECL Address Capital Concerns

Written by The Rehmann Team

The OCC, the Board of Governors of the Federal Reserve System and the FDIC have issued a proposal that could ease the impact of the Current Expected Credit Losses (CECL) policy on capital ratios. The proposal would permit allowances to count as Tier 2 regulatory capital, as well as introduce a three-year transitional period to phase-in the day-one impact on capital ratios. The proposal also amends stress testing regulations so financial institutions that have adopted CECL would not include its effect on their provisioning for purposes of stress testing until the 2020 stress test cycle. Why are the changes being proposed?..

Tuesday, 22 May 2018

Do New Revenue Reporting Rules Impact Public Bank Filings?

Written by The Rehmann Team

New guidance for the ways public companies recognize certain types of revenue (ASC Topic 606, Revenue from Contracts with Customers) went into effect in January. Since revenue is an important component investors review when considering investing in a public company, the new standard seeks to create consistency in the ways revenue is reported by strengthening disclosure requirements for reporting information about the nature, amount, timing, and uncertainty of revenue from contracts with customers. The FASB and the International Accounting Standards Board (IASB) guidance: Removes inconsistencies and weaknesses in existing revenue requirements Provides a more robust framework for addressing revenue issues Improves comparability of revenue recognition practices across entities, industries, jurisdictions, and capital markets Simplifies the preparation of financial statements by reducing the number of requirements to which an organization must refer The standard has the greatest potential impact on non-interest income, but the general consensus in the financial institutions community is that it won’t have a material impact on their income statements. Has this sentiment turned out to be true?..

Tuesday, 22 May 2018

Beneficial Ownership CDD Requirements Effective May 11, 2018

Written by The Rehmann Team

FinCEN has determined that more explicit rules with respect to Customer Due Diligence (CDD) are necessary to clarify and strengthen CDD in order to enhance financial transparency and help to safeguard the financial system against illicit use. Effective CDD helps financial institutions understand who their customers are and what types of transactions they conduct as a critical step in the fight against illicit financial activity, including money laundering, fraud, tax evasion, terrorist financing and evasion of sanctions. According to FinCEN, the key pillars of CDD that should be part of a financial institution’s BSA/AML program include: 1. Customer identification and verification2...

Tuesday, 22 May 2018

EU Regulation May Impact U.S. Financial Institutions

Written by The Rehmann Team

On May 25, 2018, the European Union’s General Data Protection Regulation (GDPR) goes into effect. It prohibits an organization conducting business within the EU or serving customers who live in the EU - regardless of where the organization is headquartered - from collecting or using personal data without the individual’s consent.  Therefore, financial institutions with global operations, even if headquartered in the U.S...

Thursday, 22 February 2018

The Impact of the Tax Cuts and Jobs Act on Financial Institutions

Written by The Rehmann Team

Tax Cuts and Jobs Act (H.R.1) On December 22, 2017, President Trump signed the Act to Provide for Reconciliation Pursuant to Titles II and V of the Concurrent Resolution on the Budget for Fiscal Year 2018 commonly referred to as, the Tax Cuts and Jobs Act of 2017 (“TCJA”). The TCJA represents the most significant overhaul of America's tax system in decades...

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