Events

Side-by-side comparison of what the new proposal contains against the previous version of the final rule – what changed and what stayed the same?
Who is covered? Examining the coverage thresholds and new timing requirements
Interplay between this rule, HMDA, and CRA reporting requirements
Who is a “covered financial institution”?
Determining what to report – covered credit transactions and covered originations
What types of applications will be reported? How is an application defined for this purpose?
Deep dive into the data points – both those generated by the lender as well as those provided by the applicant, including data elements no longer part of required collection
Collecting demographic information – forms, verifications, policies, procedures, and (fortunately) no responsibility to guess: less than beforens
The “firewall” requirement – ensuring lenders to not have improper access to the data
Safe harbor and “bona fide errors” provisions
Likelihood of finalization

Differentiating property types
Issues with owner-occupied and specialty properties, such as hotels and nursing homes
“Triple net” versus full-service leases
Other common provisions in commercial leases
Reimbursement for common area maintenance
Co-tenancy clauses
Requirements placed on the tenant vs landlord
Estoppels
Subordination, non-disturbance, and attornment provisions
Unusual or extraordinary lease provisions
Re-lease and rollover risk
Physical style risk and ongoing property management risk
Concept of sponsorship

Who has to complete the beneficial ownership certification?
What information must be retained and types of identification?
Loan Renewals, CD renewal, and other ongoing relationships
What happens when your legal entity adds an account?
What happens when the owners change on a legal entity?
What happens if the business sells?

Coverage issues
Application issues
Timing rules of TRID
Problems with disclosure of various fees
Providing a revised loan estimate
Changed circumstances
Proper calculation of tolerances/variances
Corrected CDs
Redisclosure and reimbursement after closing

Basic Notary Public laws
Responsibilities of a Notary Public
Conflicts of interest
What happens when the law and the employer don’t agree
Notarial liability and why notaries are sued

New tax on foreign remittances: What do you need to know and do
Interest deduction on car loans: Who qualifies and marketing opportunities
W-2 information on reporting overtime: Which is tax deductible and tips
Health Savings Account changes: Plan amendments and changes
Increased federal budget for farmers: Increase in crop insurance and other items
Full deduction for depreciation and other business opportunities like research and development

The scope of Section 1071 and its impact on your institution
How the lawsuits have impacted implementation
Actionable steps for implementing the new rules as efficiently as possible within your institution
The required data fields and find out how to begin collecting them
How to identify additional resources that may be required to achieve compliance, including budgeting, staffing, tools & training
Strategies for what you should be doing now
How to communicate the impact of Section 1071 on the institution to the board, senior management, and commercial lending teams
How to establish a proactive plan to acclimate employees and customers to changes in the lending process

Potential BSA changes – CTR thresholds and more
BSA FAQs: anything new?
OCC and FDIC standardization of MRAsStatus of “debanking”
Fed supervisory ratings change
Regulators: “pragmatic approach” to regulation and supervision
AI: Banks should “raise their game”
District Court enjoins 1033 enforcement
CFPB withdrawal of FCRA interpretive rule, and clarifies federal preemption of state laws
State of the CFPB: staffing and funding
CFPB rescissions: nonbank registry rule, adjudication process, nonbank form contracts
Reputation risk elimination by agencies
Rescission of climate risk principles for large organizations
OCC proposes to rescind recovery guidance