Compliance School consists of two tracks, Lending and Deposits, and is designed for entry-mid level compliance personnel. In 2023, the VBA and NCBA will join together to host the virtual school with a three day Lending track and a one day Deposits track.

Consumer loan product regulations are more complex and detailed than ever with more significant changes and guidance becoming effective at regular intervals. With greater scrutiny comes higher risk of noncompliance and the likelihood of enforcement action and/or civil money penalties.

This program offers a comprehensive discussion of consumer compliance regulations and effective assessment methods. Lenders and compliance officers will be better prepared to effectively audit, train, and manage the bank’s compliance lending requirements.

Lending Track

Consumer loan product regulations are more complex and detailed than ever with more significant changes and guidance becoming effective at regular intervals. With greater scrutiny comes higher risk of noncompliance and the likelihood of enforcement action and/or civil money penalties.

This program offers a comprehensive discussion of consumer compliance regulations and effective assessment methods. Lenders and compliance officers will be better prepared to effectively audit, train, and manage the bank’s compliance lending requirements.

Reg B: Equal Credit Opportunity Act

• Equal treatment and fair lending considerations
• Application stages: inquiries, incompletes, withdrawals, denials, and approvals
• Collection of government monitoring information
• Adverse action rules and business loan denial options
• New requirements for providing copies of appraisals and evaluations.

Fair Credit Reporting Act

• Permissible purpose
• Requirements of users of consumer reports• Duties of furnishers of information to a CRA
• Requirements relating to identity theft.

Unfair, Deceptive, or Abusive Acts or Practices (UDAAP)

• The FTC Act/Dodd-Frank Act
• Standards for determining what is unfair, deceptive or abusive.
• Deceptive acts and practices
• Abusive acts or practices
• Managing risks

Flood Disaster Protection Act

• Flood insurance eligibility and determination
• Private Policy requirements and challenges
• Required notification and acknowledgment.
• Insurance and escrow requirements
• Force placed insurance, penalties and liabilities.
• What examiners look for in a flood exam.

Reg C: Home Mortgage Disclosure Act (HMDA)

• Requirements, responsibility and reporting
• Loan application register
• Setting HMDA audit sampling sizes
• Discuss common violations.
• Discuss expanded data field.

Reg Z: Truth in Lending Act

• Coverage and exemptions
• Finance charges, annual percentage rate and amount financed
• Adjustable-rate mortgage (ARM) disclosures
• Mortgage transfer disclosure
• Right of rescission
• Higher-priced mortgage loans
• Homeownership counseling
• Ability-to-Repay / Qualified Mortgage rules

Reg X: Real Estate Settlement Procedures Act (RESPA)

• Homeownership counseling
• General disclosure requirements
• Restriction of fees
• Escrow accounts
• Mortgage servicing and error resolution procedures
• Early intervention requirements, continuity of contact, and loss mitigation procedures

Homeowners Protection Act (PMI)

• Coverage
• Cancellation and termination
• Disclosure requirements
• Civil liabilities

Reg Z: TILA-RESPA Integrated Disclosures

• Loan estimate
• Closing disclosure
• Tolerances

Military Lending Act

• Coverage
• Lending limitations / Prohibited practices
• MAPR calculation
• Disclosure requirements

Deposits Track

Consumer deposit products, services and delivery methods have changed dramatically due to the Dodd-Frank Act. Regulatory amendments and new interpretations have created an extremely complex deposit environment. This program provides a comprehensive discussion on critical deposit account rules and discusses the implications of UDAAP and the subjectivity of enforcement. Compliance officers and personal bankers will be better prepared to identify solutions in the deposit account front-line sales and operations areas.

Reg D: NOW Eligibility and Reserve Requirements

• Repeal of the withdrawal restrictions on savings and money market accounts
• Regulatory minimum and your bank’s early withdrawal penalty
• What are the reserve requirement rules? How do they impact compliance?
• Interest-bearing DDA vs. NOW accounts – they’re not quite the same.
• Interest premium rules – Do they still matter?

Reg E: Electronic Funds Transfer Act

• Disclosures and notices
• Resolving error claims
• Electronic check conversion
• Customer education
• Remote deposit capture
• Mobile banking
• Foreign remittance rules
• Payroll card and gift card rules
• Examination trends and frequent findings
• Overdraft Opt-ins

Reg CC: Expedited Funds Availability Act

• Disclosures and notices
• Implications of item posting order.
• Common hold notice errors
• Check 21
• Remotely Created Checks

Reg P: Privacy and Information Sharing “Opt Outs”

• Reg P rules
• Model form (01/01/11)
• Connection with FCRA sharing
• Do not market/Do not solicit policies.
• New CFPB annual disclosure rules

Reg S: Right to Financial Privacy

• Government information requests
• Reimbursement

Fair Credit Reporting Act/ID Theft “Red Flags”

• Address discrepancies
• Credit report alerts
• Other “red flags”
• Affiliate marketing
• Annual report

Reg DD: Truth in Savings Accounts (TISA)

• Disclosures and notices
• Unfair, Deceptive, or Abusive Acts or Practices (UDAAP)
• The higher-risk parts of the rules (e.g., inconsistent terminology, products/terms changes)
• Advertising compliance
• Common disclosure errors
• Courtesy Overdraft Programs