Regulatory HMDA
• • Requirements are overly
burdensome and costly.
• Additional HMDA data elements
needing to be collected can result
in increased reporting errors and
additional staff time devoted to
data collection.
•
•
Excessive cost of compliance
not being offset by increases in
revenue.
HMDA reporting requirements
making it challenging for banks to
increase their mortgage lending
activities.
Rules and regulations negatively
impacting community banks
because they were written for
large banks, ultimately making it
harder to improve profitability.
TRID
•
•
•
Disclosure requirements being
costly, resulting in a large
volume of paperwork, confusing
to consumers and ultimately
impacting mortgage profitability.
Qualified mortgage-rule
restrictions (debt-to-income
limitation) making it challenging
to fund purchase money
residential mortgages.
Ensuring adequate and
consistent compliance training for
staff.
BSA
•
Beneficial ownership rules being
too complex and burdensome on
staff and customers, as well as
costly and delaying the opening
of accounts. This puts institutions
in a position of “policing”
customers’ behavior.
•
•
Beneficial ownership rules are
onerous to small community
banks that already know their
customers and have customer
identification procedures in place.
•
Potential for HMDA requirements
becoming applicable to certain
commercial loans.
Marijuana
• The need for greater transparency
in examination procedures
regarding marijuana-related
businesses.
• Clearer regulatory guidance
and expectations are needed to
aid institutions in determining
whether to provide services to
cannabis or industrial hemp-
related customers.
•
Conflicting state and federal laws
resulting in BSA requirements
becoming taxing.
After regulatory issues, the next
biggest topic of interest was
examination issues, more specifically
consumer compliance and BSA.
The Ombudsman Office is assuming
the lead role in soliciting post-
examination survey responses
after each consumer compliance
examination conducted by FDIC
examiners. lll
Topics of Interest
Breakdown
26%
Regulatory Burden
16%
Truth in Lending and
Real Estate Settlement
Procedures Act (TRID)
15%
Bank Secrecy Act (BSA)
7%
Home Mortgage
Disclosure Act (HMDA)
5%
Marijuana
31%
Non-Compliance Items
The $10,000 threshold for
Currency Transaction Reports
is outdated and should be
increased.
11