compliance monthly

June 2015
Compliance Monthly is intended to keep you informed of regulatory changes in advance of their effective
date so your institution can have the necessary policies, procedures and processes in place to be compliant
at the time of enactment.
Finalized Rules:

Minimum Requirements for appraisal

management companies rule

A joint press release has been issued by the six

federal financial regulatory agencies (OCC, FRB,
FDIC, CFPB, FHFA and NCUA) announcing the
issuance of a final rule that implements minimum
requirements for state registration and supervision
of appraisal management companies (AMCs).
An AMC is an entity that provides appraisal
management services to lenders or underwriters or
other principals in the mortgage market. The rule
was issued under the Dodd-Frank Act. The rule does
not require states to regulate AMCs, but if states
do, AMCs must register in the state, use only statecertified or licensed appraisers for federally related
transactions and ensure appraisals are independent.
In states that do not establish an AMC regulatory
structure within three years, non-federally regulated
AMCs may not provide services for federally related
transactions, such as loans backed by Fannie or
Freddie.
Federally regulated AMCs will be required to meet
the same standards as state-regulated companies,
with the exception of a requirement for state
registration. The rule is effective 60 days upon
publication in the Federal Register.
Proposed Rules:
None.

Other Compliance News:

CFPB updates rulemaking Schedule for

2015-16

The CFPB updated its rulemaking agenda for

the remainder of 2015 and into 2016. The much
anticipated Home Mortgage Disclosure Act
expansion is expected to be finalized this summer. A
final rule tweaking the rural and underserved area
definitions in the Ability-to-Repay Rule is expected
by the fall, with another final rule on successors in
interest expected next spring. The CFPB is expecting
to issue a final rule on prepaid products by early 2016
and a proposed rule on payday and auto title loans
later in 2015. The CFPB is still conducting research on
potential rulemakings on overdrafts, debt collection
and arbitration.

agencies Release 2015 Guide to CRA

Data Collection and Reporting

The FFIEC has released the 2015 Guide to CRA Data

Collection and Reporting. The comprehensive
Guide provides a summary of responsibilities and
requirements, directions for assembling the necessary
information and instructions for reporting CRA data.

Agencies Revise Exam Procedures for

TILA-RESPA Integration
The federal banking agencies issued revised
examination procedures and exam manual
narratives for consumer compliance rules under
the Truth in Lending Act (TILA) and the Real Estate
Settlement Procedures Act (RESPA).

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Compliance Monthly
June 2015

Most of the changes to the procedures relate to the

integrated mortgage disclosure requirements under
TILA and RESPA, commonly referred to as the TRID
requirements. The revised interagency procedures
will go into effect August 1, 2015. These interagency
procedures reflect:

New requirements for integrated mortgage
loan disclosures under TILA and RESPA;

Amendments to Regulation Z that extend the
post-rate lock timing for a revised loan estimate; and

Special provisions on certain construction
loans.
Copyright 2015 Accume Partners, All rights reserved.
Information contained in Compliance Monthly is not intended to
provide specific advice and guidance. You should consult your own
professional services provider in connection with matters affecting
your own interests.

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Compliance Monthly
June 2015

about accume partners

Accume Partners provides the financial industry with regulatory compliance, internal audit, technology
and enterprise risk management services. Through these key areas of focus, Accume is able to remain at
the forefront of changing needs and regulations of its clients, bring balanced perspectives and the specialized
knowledge necessary to serve todays banks and financial institutions.

To learn more, please visit our website at accumepartners.com.

For more information, please call or e-mail any of these Accume Partners contacts:
Steven Peck
Managing Director, Compliance
610.803.1617
speck@accumepartners.com

David Smith
Director, Compliance
570.606.7423
dlsmith@accumepartners.com

James Nemecek
Director, Compliance
215.565.6576
jnemecek@accumepartners.com

Mark Lindig
Chief Executive Officer
646.476.1961
mlindig@accumepartners.com

Paul Nobbs
Managing Director, NJ Banking
and
Financial Services
609.332.7132
pnobbs@accumepartners.com

Nicole Lloyd
Managing Director, Mid-Atlantic
717.903.3142
nlloyd@accumepartners.com

Glenn Hoffman
Managing Director, Technology
Risk
Management
203.803.7345
ghoffman@accumepartners.com

K.D. Mehra
Managing Director, NY Banking
347.576.5652
kmehra@accumepartners.com

1.888.696.1515 accumepartners.com
Copyright 2015 Accume Partners, All rights reserved.