TOPIC: Compliance

Positive Aggregate Adjustment on Closing Disclosure

Employee at a bank ($217MUSA)
We currently use Compliance One Mortgage software to prepare our TRID docs. We recently encountered a positive aggregate adjustment on a closing disclosure increasing the borrower's Cash to Close. I have always been under the impression that aggregate adjustments can only be a negative number or zero. In reviewing how this was calculated, the annual property tax amount could not be evenly divided by 12. Through the calculations, the software recognized that there would be an escrow balance deficit of $0.04 after all payments had been made. However, it would be a $0.04 deficit to the bank's selected 2 month cushion. The escrow account balance, assuming the customer makes all payments, would be positive. The software then was collecting for this cushion deficit upfront in the aggregate adjustment.  We have researched our software parameters and it appears that there is no way to change this or manually complete the calculation. Compliance One legal claims this can be a positive number, a negative number or zero. I'm looking for some additional guidance on this, can we have a positive aggregate adjustment, and can we collect for a projected deficit upfront? 

    Blog | RPA: Improve Efficiency and Increase Productivity by Automating Routine Tasks - Read now

    RPA: Improve Efficiency and Increase Productivity by Automating Routine Tasks
    FIs Save Time and Money Implementing Robotic Process Automation

    September 4, 2019 by Verafin

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    Is your financial intelligence unit challenged by limited time and resources? Are your BSA/AML and Fraud investigators spending more time manually collecting data than investigating potentially suspicious activity?

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      MSB Security Deposit

      SVP at a bank ($3.3BUSA)
      Would like to get a poll as to what other banks may require to be on deposit when banking an MSB to cover possible chargebacks after or when a MSB relationship ends. We currently have several MSBs that we do not require any sort of deposit and are concerned that should we or the MSB close the relationship, how do we ensure we get covered for any possible chargebacks that may come after the accounts are all closed?


        Asset Verification

        Manager at a credit_union ($291MUSA)
        Good morning, 

        We received an asset verification request from a local assisted living facility.  For this verification they asked us the RMD value for our member.  I've never been asked for this before, has anyone else?  Is this within their rights to know this information? 

        Thank you for any assistance. 

          Debt Protection - Tax Implications

          VP at a credit_union ($936MUSA)
          Does anyone here report 1099s on benefits received for debt protection? Can you provide the reason and support for reporting or not reporting.  Our vendor is stating that they have no clients that are sending 1099s on benefits received.  However the contract with our vendor puts the burden of reviewing this point on us.  I appreciate any thoughts or feedback you can provide on this subject.    

            News Alert: 7 Fast Facts about the Just-Released 2018 HMDA Peer Data

            Last week, on August 30, the FFIEC released the 2018 HMDA data, aggregated into one file. This HMDA data is a powerful and essential resource for the industry. Here are 7 fast facts your financial institution need to know:

              Educational Webinar | Employee Fraud: Understanding the Threat from Within - Join us Sept 4

              September 04 at 12:30 PM - 01:30 PM EST
              Employee Fraud: Understanding the Threat from Within
              The role of monitoring in reducing the reputational and financial risks of internal fraud

              Register Now

              Financial institutions are especially vulnerable to employee fraud, as fraudsters within the organization have access to large amounts of personal identification information and financial transactional data, along with access to customer accounts. Join us as we discuss how such schemes can add up to significant fraud losses, the financial and reputational risks, and how employee fraud can also enable other illicit activity.

              In this presentation, you will learn:
              • The scale of the crime of employee fraud, including the potential for losses and compliance considerations
              • Review tactics internal bad actors use to commit fraud against financial institutions
              • Best practices to mitigate losses and protect your institution from internal threats, including appropriate monitoring and fraud controls
              Register Now