Compliance Town Hall Year in Review and Year Ahead · Credit cap of 36% now includes: payday loans,...
Transcript of Compliance Town Hall Year in Review and Year Ahead · Credit cap of 36% now includes: payday loans,...
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Compliance Town Hall
Year in Review and Year Ahead
Eleanor Hopkins, NCCO
Product Manager, Compliance
December 15th , 2016
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2This presentation does not provide legal advice.
Enhancement dates contained in this document
are provided as estimates only and can be
changed at any time at the sole discretion of Jack
Henry & Associates, Inc.
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3This presentation does not provide legal advice.
Speaker Information
Eleanor Hopkins, NCCO
Episys Product Manager, Compliance
Symitar, a Jack Henry & Associates Company
Tel: (619) 542 - 6839
E-mail: [email protected]
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4This presentation does not provide legal advice.
Agenda
2016 in Review
2017 Preview
Future
Product Announcements
Resources
Questions
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2016 in Review
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6This presentation does not provide legal advice.
2016 in Review: Political Climate
CFPB Structure Ruled Unconstitutional (CFPB v. PHH
Corporation)
CFPB requested a rehearing– results are outstanding
2016 Election Results
Republican President-Elect Trump
Republicans dominate House and Senate
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7This presentation does not provide legal advice.
2016 in Review: Political Climate
Many possible outcomes:
Restructuring of the CFPB?
Selecting a new CFPB director?
Restricting CFPB budget?
Repeal of Dodd-Frank?
Or repeal of provisions within Dodd-Frank (e.g. Durbin
Amendment)?
Regulatory relief for credit unions and banks?
Will big banks (e.g. Wells Fargo) still be held
accountable?
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8This presentation does not provide legal advice.
2016 in Review: Political Climate
Possible moratorium on regulations in flight (ANPR,
PR)?
Difficult to manage a compliance program on speculation.
Recommendation: compliance should focus on the
finalized rules, keep an eye on the proposed, stay aware
of the politics.
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9This presentation does not provide legal advice.
2016 in Review: Wells Fargo
Fine $185 million – more than 2 million bank accounts
opened or applied for without customer knowledge
FBI and state federal investigation
Senate Banking hearing, “claw back executive pay”
In wake of scandal, Wells Fargo CEO John Stumpf
retired
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10This presentation does not provide legal advice.
2016 in Review: Wells Fargo
Impact to industry: CFPB issued a warning:
Don’t open an account without consent
Don’t misrepresent the benefits of a product
Don’t steer consumers towards less favorable products or
terms
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11This presentation does not provide legal advice.
Regulation Effective
Homeowner Flood Insurance Affordability Act of 2014 1/1/16
IRS 1098 Changes – Surface Transportation & Vet Health Care
Choice Act
Tax Yr 2016
Report in 2017
CFPB Further Amendments 2013 Mortgage Rules (Reg X & Z)
• QM Rule & DTI Calcs for QM
• Ability to Repay
• Small Creditor in Rural & Underserved
1/1/16
CFPB Reg Z Dollar Threshold – Same as Prior Year 1/1/16
DOE Student Loan Disbursement 6/1/16
NACHA Same Day Settlement 9/23/16
9/15/17
3/16/18
DOD Military Lending Act (MLA) 10/3/16
10/3/17
FinCEN 314(a) Update ?
2016 In Review: Rules Effective 2016
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12This presentation does not provide legal advice.
2016 in Review: IRS 1098 Changes
Surface Transportation and Veterans Health Care Choice
Improvement Act of 2015 made changes to IRS Form 1098
Principal at beginning of year
Origination Date
Address
Effective: 2016 data reported in 2017
Impact to Episys: Capture Mortgage Data for 1098
Reporting
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13This presentation does not provide legal advice.
2016 in Review: NACHA Same Day
Amend the NACHA Operating Rules to enable the same-
day processing of virtually any ACH payment.
Phase 1 – Same day settlement of credit entries and non
monetary entries:
Effective: September 23, 2016
Phase 2 – Same day debits and utility type payments:
Effective: September 15, 2017
Phase 3 – RDFI Must make funds available by 5:00 pm
local time:
Effective: March 16, 2018
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14This presentation does not provide legal advice.
2016 in Review: NACHA Same Day
Impact to Episys: None
Resources: For Clients > Products & Services > Core
Solution > Episys > Announcements & Alerts > Episys
and NACHA Same-Day Settlement Rule Update
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15This presentation does not provide legal advice.
2016 in Review: DoD MAPR
The Department of Defense (DoD) expanded the Military Lending Act
(MLA) to prevent abusive lending practices for active duty service
members:
Credit cap of 36% now includes: payday loans, deposit advance
products, auto title and installment loans.
Credit cap excludes: residential mortgages, loans secured by property
being purchased.
Military APR modified to include certain fees as part of the calculation
Effective October 3, 2016 (open and closed loans)
Effective October 3, 2017 (credit cards)
Impact to Episys : Rate Cap for Military APR; Credit
Card MAPR; ELA Enhancements
Target: 2016.00, 2017.00
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16This presentation does not provide legal advice.
Military Lending Act Timeline
Dec
R 2016.01Nov
Oct
MLA effective
• Dfct1117650 fix
• ELA update
Sept
• Rate Cap for Military APR
June
R 2016.00
Dec
R 2017.01
Oct
MLA Credit Cards
effective
June
R 2017.00Feb
2016
2017
• Rate Cap for Military APR –Part 3
• Credit Card MAPR CAP
• ELA Update
Credit
Retrieval -
Military
Lending Act of
2016
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17This presentation does not provide legal advice.
2016 in Review: FINCEN 314 (a) changes
FinCEN modified the 314(a) report to include IP Addresses,
email addresses and website addresses as part of a
search.
Effective: September 1, 2016 for law enforcement, no
specifications for formal effective date provided for Fis
Impact to Episys: FinCEN 314(a) PowerOn Specfile
Modification
Target: Available now for download and in Jan SP
Products & Services > Core Solution > Episys >
Release Information > PowerOn Programs
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2016 in Review: Enhancements
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19This presentation does not provide legal advice.
2016 in Review: Enhancements
Release 2016.00
NCUA Share Insurance Report Update
Rate Cap for Military APR
Capture Mortgage Data for 1098 Reporting
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20This presentation does not provide legal advice.
NCUA Share Insurance Report Update
Updates the NCUA Share Insurance Report calculations
to ensure accurate share insurance coverage and of
members and premiums paid.
2016 in Review: Enhancements
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21This presentation does not provide legal advice.
Rate Cap for Military APR
Enhance Episys to support the 36% rate cap
expansion under DoD amendments to the
Military Lending Act
New flag to indicate MAPR qualified loan and or person
ID loans at risk for MAPR 36% threshold limit
MAPR includes Reg Z Fees and more, this project will
provide the means to id those new fees
Insurance and Fees charged to the share for a loan are
addressed
2016 in Review: Enhancements
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22This presentation does not provide legal advice.
2016 in Review: Enhancements
Capture Mortgage Data for 1098 Reporting
Support new data requirements for mortgage loan
reporting on IRS form 1098 for tax year 2016.
Provide the ability to store the outstanding principal at
beginning of calendar year
Provide the ability to store the full property address (street,
city, state and zip) and description (such as parcel
number)
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23This presentation does not provide legal advice.
2016 in Review: Enhancements
Capture Mortgage Data for 1098 Reporting
Actions for You:
Load Release 2016.00
Update the new fields before December 31st, 2016
Property Information fields
Beginning Year Loan Balance field
Trial Balance Report
PowerOn specfile: UPDATE.BEGGINNING.BALANCE
Resources: For Clients > Products & Services > Core
Solution > Episys > Announcements & Alerts
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24This presentation does not provide legal advice.
2016 in Review: Enhancements
Release 2016.01
Expire Temp Passwords
Amendments to the 2013 Mortgage Rules:
Statements, DQ, and Formatting (Part 1)
2016 IRS Reporting Changes
FinCEN 314(a) PowerOn Specfile Modification
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25This presentation does not provide legal advice.
2016 in Review: Enhancements
Expire Temporary Passwords
Provide the ability to expire temporary passwords
after a reasonable time.
The User Temp Password Exp Hours parameter to
Miscellaneous Parameters.
The Temp Password Expiration Date field to the User record.
The Temp Password Expiration Time field to the User
record.
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26This presentation does not provide legal advice.
2016 in Review: Enhancements
Expire Temporary Passwords
Actions for You:
Update the new parameter User Temp Password Exp
Hours in Miscellaneous Parameters to a value from 1 to 96
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27This presentation does not provide legal advice.
Amendments to the 2013 Mortgage Rules:
Statements, DQ, and Formatting (Part 1)
Provide the option to include an explanatory note below various
segments of the periodic statement. First piece of solution for
regulation, non functional pieces added to database
Data changes required to support statement message and
statement loan notes
Statement note option
New loan record fields
New Parameter manager category
Actions for You:
None
2016 in Review: Enhancements
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28This presentation does not provide legal advice.
2016 IRS Reporting Changes
Annual IRS paper forms, electronic forms and COLA
changes.
Actions for You:
Recommended steps for 1098 Reporting of mortgage
information
2016 in Review: Enhancements
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29This presentation does not provide legal advice.
FinCEN 314(a) PowerOn Specfile
Modification
Updated the RB.FINCEN PowerOn Specfile to
include member email address in the search criteria
and results report.
Actions for You:
Download updated RB.FINCEN
Load January SP
Resources: Products & Services > Core Solution >
Episys > Release Information > PowerOn Programs
2016 in Review: Enhancements
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30This presentation does not provide legal advice.
Resources: Episys Release Information
Resource Details Where To Find It
NACHA SameDay FAQ
JHA’s position on the Same Day ACH changes & FAQ
For Clients > Products &
Services > CoreSolution > Episys > Announc
ements & Alerts > Episys and NACHA Same-
Day Settlement Rule Update
SymitarRegulatory News Report
Quarterly compliance newsletter – glimpse into regulations Symitar is monitoring.
For Clients > Compliance > Compliance Newsletters
SymitarCompliance Projects Summary
High level summary of all compliance enhancements in process as well as a handful of compliance hot topics
For Clients > Products & Services > Core Solution > Documentation > Compliance
Release Overview Class
Video replay that offers a high level review of enhancements
For Clients > Products & Services > Core Solution > Episys > Release Information > Episys Releases > Release Documentation
Release Executive Summary
List of enhancements in the release
For Clients > Products & Services > Core Solution > Episys > Release Information > Episys Releases > Release Documentation
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2017 Preview
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32This presentation does not provide legal advice.
Regulation Effective
TCPA Amendments 1/15/17
NACHA Same Day 9/15/17
NACHA – Third Party Sender Registration 9/27/17
The Consumer Data Industry Association (CDIA)
– National Consumer Assistance Plan
9/15/2017
CFPB Prepaid Consumer Accounts 10/1/17
10/1/18
CFPB Amendments to the 2013 Mortgage Servicing Rule 10/19/17
4/19/18
DoD Military Lending Act (MLA) 10/3/16
10/3/17
CFPB HMDA 1/1/17
1/1/18
Revised Uniform Residential Loan Application (URLA) 1/1/2018
2017 Preview: Rules Effective 2017
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33This presentation does not provide legal advice.
2017 Preview: TCPA Amendments
Telephone Communication Protection Act (TCPA)
The amendment creates a special exemption for debt
collection calls made by the US government or it’s contractor
to collect a debt owed or guaranteed by the US.
Credit Unions, even if they service a federal loan, do not
qualify as a contractor.
Effective: January 15, 2017
Impact to Episys: None
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34This presentation does not provide legal advice.
2017 Preview: Consumer Data Guide
Credit Bureaus implemented the National Consumer
Assistance Plan to improve collection of accurate
consumer data, while increasing transparency for
consumers.
For accounts opened after 9/15/2017, data furnishers
must report:
Full Name, Generation Code, Suffix
Address
Full SSN
DOB
Effective 9/15/2017
Impact to Episys: None
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35This presentation does not provide legal advice.
2017 Preview: Amendments to the 2013
Mortgage Servicing RuleClarification on delinquency, requests for information
related to Fannie/Freddie loans, amendments to force-
place insurance disclosures and model forms, early
intervention obligations, clarification on loss mitigation,
prompt payment crediting and more.
Effective: October 19, 2017 & April 19, 2018
Impact to Episys: Amendments to the 2013 Mortgage
Rules: Statements, DQ, and Formatting
Targeted Releases 2016.01, 2017.00 and 2017.01
Resources: Updated CFPB Small Entity Compliance Guide
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36This presentation does not provide legal advice.
2017 Preview: HMDA
Home Mortgage Disclosure Act (HMDA) (Reg. C).
Expanded loan type reporting and additional data for
reporting loan applications
Age & credit scores
Points, fees & APR offered vs benchmark
Terms for: prepayment penalty, loan, introductory
interest rates, collateral value
Effective: January 1, 2018
Impact to Episys: HMDA Reporting Modifications
HMDA Data Entry Screen
Targeted Release 2017.00
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37This presentation does not provide legal advice.
2017 Preview: HMDA
Special notes on HMDA data elements:
Legal Entity Identifier (LEI)
Would be unique to the institution – and likely needs to be
stored somewhere with Branch Information.
Universal Loan Identifier (ULI)
Is unique to the loan, and probably should be on the loan
record
Impact to Episys: HMDA Reporting Modifications
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38This presentation does not provide legal advice.
2017 Preview: HMDA, URLA Changes
CFPB adopted a final Rule supporting Fannie Mae’s
changes to the Uniform Residential Loan Application
(URLA) and Collection of Expanded Home Disclosure Act
Information about Ethnicity and Race in 2017 (under Reg
B).
For now 1992 URLA meets provisions of Reg B.
Effective: you MAY gather data in 2017
Impact to Episys: None, Episys does not support
Fannie Mae loans
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2017 Preview: Enhancements
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40This presentation does not provide legal advice.
2017 Preview: Enhancements
Release 2017.00
Amendments to the 2013 Mortgage
Rules: Statements, DQ, and Formatting (Part 2)
Rate Cap for Military APR (Part 2)
Credit Card MAPR Cap
HMDA Reporting Modifications
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41This presentation does not provide legal advice.
2017 Preview: Enhancements
Amendments to the 2013 Mortgage Rules:
Statements, DQ, and Formatting
Final charge off statement
DQ section – adding custom temp loss
mitigation information
Close proximity rule (intervening text)
Statement requirements for a loan in temporary
loss mitigation, acceleration
Effective: October 19, 2017
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42This presentation does not provide legal advice.
2017 Preview: Enhancements
Rate Cap For Military APR (Part 2)
Enhance Episys to support the 36% rate cap
expansion for open-end and closed-end loans
under DoD amendments to the Military Lending
Act.
Effective: October 3, 2016
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43This presentation does not provide legal advice.
2017 Preview: Enhancements
Rate Cap for Military APR (Part 2)Ensure consistent work flows for loan application process to support
newly required information.
Ensure that the Application Person record has the four new fields (Act.
Duty V Date; Act. Duty Start Date; Act Duty Sep Date; Act Duty).
Ensure the Application Record has the new Military APR Status field.
Ensure that RD.LOAN.CALCULATE.MAPR and Reg Z calculates the
Interest from Statement Date +1 thru Transaction End Date.
Ensure the closed-end loan MAPR/APR calculations in the Loan
Projection Screen are accurate for 360 Actual and Variable Payment
Loans.
Provide the ability to call Projections calculation of MAPR from a
specfile.
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44This presentation does not provide legal advice.
2017 Preview: Enhancements
Credit Card MAPR
For Credit Cards, enhance Episys to support the 36% rate
cap expansion under DoD amendments to the Military
Lending Act.
Provides the ability to exclude or include fees that are
not “reasonable” and or “bonafide” in the MAPR
calculation for credit cards.
Effective: October 3, 2017
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45This presentation does not provide legal advice.
2017 Preview: HMDA
HMDA Reporting Modifications
Provides the ability to store new HMDA reporting data
elements in Episys.
HMDA Data Entry Screen
Enhanced Lending Application (ELA)
Resources: For Clients > Products & Services > Core Solution > Episys
> Announcements & Alerts > Home Mortgage Disclosure Act (HMDA)
Data Collection Enhancements
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46This presentation does not provide legal advice.
2017 Preview: Enhancements
Release 2017.01
Amendments to the 2013 Mortgage
Rules: Statements, DQ, and Formatting (Part 3)
SBA 1502 Reporting Enhancement
FinCEN Customer Due Diligence
2017 IRS Reporting Enhancement
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47This presentation does not provide legal advice.
2017 Preview: Enhancements
Amendments to the 2013 Mortgage Rules:
Statements, DQ, and Formatting
Enhances the mortgage statement to meet
regulatory amendments, including treatment of
delinquencies, charged off loans, early
intervention, close proximity and loss mitigation.
Successor in Interest
Bankruptcy
Effective: April 19, 2018
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48This presentation does not provide legal advice.
2017 Preview: Enhancements
SBA 1502 Reporting Enhancement
Project provides fixes for several SBA 1502
Reporting defects involving incorrect data being
reported.
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49This presentation does not provide legal advice.
2017 Preview: Enhancements
FinCEN Customer Due DiligencePurpose: clarify and strengthen customer due
diligence (CDD) obligations of financial institutions.
Know and verify the identities of beneficial owners who
own, control, and profit from the companies they service.
Beneficial owner is either
A. Ownership - 25% or more equity interest
B. Control – maintains significant responsibility to control, manage
or direct the legal entity
Effective: 5/11/2018
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50This presentation does not provide legal advice.
2017 Preview: Enhancements
IRS 2017 Reporting
Updates for 2017 IRS reporting changes to the
IRS forms and electronic files
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Future
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52This presentation does not provide legal advice.
Future: FASB CECL
FASB ALL Standards Change – Current
Expected Credit Losses (CECL)
Financial Accounting Standards Board (FASB) modified
the methodology accounting for impairment of financial
instruments that will result in an increase loan loss
provisions
Old methodology: Incurred Loss Model, fund the ALLL
via provision expense after loss is incurred or probable
New methodology: Current Expected Credit Loss
(CECL), recognize expected lifetime losses at
origination
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53This presentation does not provide legal advice.
Future: FASB CECL
How will you be impacted?
Loan loss allowance could be significantly greater under
the new method
Increase in provision will decrease net income and
capital
Increase in costs and time to prepare and audit the ALLL
Recommend finding a solution and begin data
gathering early.
Effective: December 15, 2021
Impact to Episys: None – all data elements are
on the core
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54This presentation does not provide legal advice.
Future: Enhanced Cyber Risk
Management
Joint Agency – Cyber Management
Enhanced cybersecurity risk-management and resilience
standards that apply to largest and interconnected
entities of $50 billion and greater.
Effective: TBD (Proposed 10/26/16)
Impact to Episys: None
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55This presentation does not provide legal advice.
Future: Fed Reserve ISO 20022
Federal Reserve Financial Services is leading an
investigation on adopting International Standards of
Organization (ISO) 20022 standards for both ACH and
Wire Transactions.
Effective: TBD
Impact to Episys: changes to Wires, ACH and
new Clearing House payment options
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56This presentation does not provide legal advice.
Future: CFPB Reg CC
Amendments to condition a depositary bank’s right of
expeditious return on the depositary bank agreeing to
accept returned checks electronically either directly or
indirectly from the paying bank; amendments to funds
availability schedule; and revisions of the model forms
used to disclose funds availability policies.
Effective: TBD
Impact to Episys: Reg CC Flexible Check
Holds enhancement
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57This presentation does not provide legal advice.
Future: CFPB Payday Loans
Payday, Vehicle Title, and Certain High-Cost Installment
Loans
Proposed rule to provide new protections for consumers
for short term high cost loans. Includes requirements to
ensure borrower can repay the loan, restrictions if
borrower has certain outstanding loans, and limitations
on repayment withdrawals.
Effective: TBD
Impact to Episys: none expected
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58This presentation does not provide legal advice.
Future: CFPB Overdraft
The CFPB has engaged in research regarding overdraft
practices involving the opt-in process for ATM and one-
time debit card transactions, overdraft coverage limits,
transaction posting order practices, overdraft and
insufficient funds fee structure, and involuntary account
closures. They have also begun consumer testing
initiatives relating to the opt-in process.
Effective: TBD
Impact to Episys: TBD
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Future Enhancements
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60This presentation does not provide legal advice.
Future Enhancements
Telephone Consumer Protection Act
Reg CC Flexible Checkhold Options
… and more to come
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61This presentation does not provide legal advice.
Future Enhancements: TCPA
The Telephone Consumer Protection Act (TCPA),enacted in
1991, limits the use of phone calls and text messages for
both telemarketing and informational purposes –
particularly with pre-recorded phone calls (robo-dialing).
Future enhancement will provide the ability to store
affirmative consent for telephone contact via a
specified phone number on the core.
Targeted Release: 2018.00
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62This presentation does not provide legal advice.
Future Enhancements: Reg CC
Reg CC Flexible Checkhold Options
This enhancement will update Reg CC parameter
checkhold options to correspond with pending CFPB
changes.
Provide flexible check hold options.
Update check hold day verbiage (local/non-local)
Targeted Release: 2018.00
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Product Announcements
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64This presentation does not provide legal advice.
OFAC PowerOn® Specfile
Product End of Support
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65This presentation does not provide legal advice.
Bridger Insight®
XG SLA
• February 2016
Integration and phase
out SLA
• August 2016
End of support
for OFACspecfiles
• December 2017
OFAC specfiles
pulled from Episys®
• Release 2018.00
OFAC PowerOn® Specfile
Product End of Support
Shop for a new solution: December 2016 – December 2017
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66This presentation does not provide legal advice.
OFAC PowerOn® Specfile
Product End of Support
Contact
If you have any questions about the Episys® Identity and
Sanctions Screening Integration or LexisNexis® OFAC
Bridger Insight® XG products, please email the Symitar
Inside Sales Team at [email protected].
Resources: Episys Now
https://pages.jackhenrymail.com/episys
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67This presentation does not provide legal advice.
ProfitStars® CECL Calculator
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68This presentation does not provide legal advice.
ProfitStars Financial Performance Suite
For further product information contact:
Lesley Karstens
Resources: Episys Now
https://pages.jackhenrymail.com/episys
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Resources
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70This presentation does not provide legal advice.
Resources: Episys Compliance
InformationResource Details Where To Find It
Symitar Compliance Town Hall Webinars
Quarterly webinar on compliance topics, future projects and resources for your credit union
Episys NOW
URL: https://pages.jackhenrymail.com/episys
SSAE 16 Episys SSAE 16 audit results of Episys and Outlink
For Clients > Compliance > Audit/Examination Information
Symitar Vendor Management FAQ
Useful document to reference during your NCUA examinations
For Clients > Compliance > Audit/Examination Information
Security White Papers & Position Statements
Responses to new security threats and vulnerabilities, recommendations for best practices
For Clients > Products & Services > Core Solution > Episys > Announcements & Alerts > Show Archived Items
Episys Discussion Boards
Client only discussion forum where you can connect with your credit union peers
For Clients > Collaboration > Discussion Boards > Episys Discussion Boards
JHA CybersecurityPreparedness
JHA’s Cybersecurity Program and Oversight
For Clients > Compliance > Audit/Examination Information
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71This presentation does not provide legal advice.
Resources: Industry Compliance
Resource Details Where to find it
CFPB Amendments to the Mortgage Servicing Rules Compliance Guide: Updated
Incorporates amendments
made to mortgage servicing
provisions in Regulation X
and Regulation Z by the
2016 Mortgage Servicing
final rule.
https://s3.amazonaws.com/file
s.consumerfinance.gov/f/docu
ments/201611_cfpb_Mortserv
_guide_v3.pdf
CFPB Fall 2016 Rule Making Agenda
Helps you forecast what
regulatory changes will
come next
Reginfo.gov
FFIEC’s FAQ for Cybersecurity Assessment Tool
Provides support,
clarification for the
Cybersecurity Assessment
Ffiec.gov
NCUA MLA exam procedures
Outlines how credit unions
will be evaluated for MLA
compliance
NCUA.gov
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72This presentation does not provide legal advice.
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73This presentation does not provide legal advice.
Contact
Eleanor Hopkins
Episys Product Manager, Compliance
Symitar, a Jack Henry & Associates Company
Tel: (619) 542 - 6839
E-mail: [email protected]
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Do you have any questions?
This presentation does not provide legal advice.