FinCEN exemptive relief ending UDAAP – The long-term risk Speaking of UDAAP: TCF overdrafts update Voicemail, phone call, and email etiquette Loans to candidate campaigns FinCEN exemptive relief ending By John S. Burnett On May 16, FinCEN issued a ruling (FIN-2018-R002) providing a “90-day limited exemptive relief” from the obligations of the Beneficial Ownership Requirements for Legal Entity Customers. The …

Reefer madness Update: campaign committee, PAC and political party accounts More on the Beneficial Ownership Rule Policies – Part 2 EGRRCPA and HMDA AML/BSA Q&As Reefer madness By Pauli Loeffler Even before State Question 788 passed, we received a lot of questions about banking marijuana related businesses (“MRBs”) mostly dealing with businesses selling CBD (short for “cannabidiol”) oil, and medical …

• Deregulation is a reality • Consumer loan dollar amounts adjust July 1 Deregulation is a reality By Andy Zavoina On May 24, 2018, President Trump signed into law, the “Economic Growth, Regulatory Relief and Consumer Protection Act” (the “Regulatory Relief Act,” P. Law 115-174, formerly S. 2155). It eases some of the regulatory restrictions imposed since the financial crisis …

Beneficial ownership rules update Policies Appraisals Beneficial ownership rules update By John S. Burnett By the time you read this, the May 11, 2018, compliance date for FinCEN’s Beneficial Ownership requirements will be only a couple of days away or already have past. As you know by now, FinCEN issued a second set of FAQs on the Beneficial Ownership requirements …

 Watch that tax advice! Credit reports are changing again Telephone Consumer Protection Act – Update Sellers’ cost on borrowers’ closing disclosures Watch that tax advice! By Andy Zavoina When it comes to tax deductibility, “watch that tax advice.” Let’s get straight to the point, considering it is April and income taxes are due. I want to caution banks, and especially …

OBA website update, Legal Briefs and Legal Links Without the App, you can’t comply with HMDA A Revised USA PATRIOT Act/CIP Sign? HMDA Signage Correction Spirit and Intent, SCRA and BMW The Beneficial Ownership Rule UBO:  How low do you go?   OBA website update, Legal Briefs and Legal Links By Pauli D. Loeffler It has been more than a …

“I received a child support levy…” Tax Refund Checks The ADA and the WWW Prepaid Accounts Rule Amended and Delayed Payday Lending Rule Likely to be Rescinded or Trimmed