Without further action by Congress to reauthorize the National Flood Insurance Program (NFIP), the authority of the Federal Emergency Management Agency (FEMA) to issue new federal flood insurance policies will expire on December 16, 2011.  The... [More]

Institutions and their mortgage loan originators (MLOs) that are Federally Registered are required to renew their registrations using the Nationwide Mortgage Licensing System and Registry (NMLS) each year.  The 2012 renewal period began on Nov... [More]

As of January 1, 2012, your regulators will be assessing your financial institution’s Internet Banking practices at a higher standard. The FFIEC Supplement to Authentication in an Internet Banking Environment (issued on June 28, 2011), an upd... [More]

“Whether 'tis nobler in the mind to suffer the slings and arrows of outrageous regulation,Or to take arms against a sea of troubles, and by opposing end them?” Oddly enough when I think Dodd-Frank, this Shakespearean passage pops into my... [More]

Multiple requirements have been added to the Fair Credit Reporting Act (FCRA) in recent years, including those related to:• Requirements to detect, prevent, and mitigate identity theft• Issuance of credit cards to consumers who ha... [More]

Section 941 of the Dodd-Frank Wall Street Reform and Consumer Protection Act (DFA) mandates that mortgage originators have “skin in the game” by retaining at least 5 percent of the credit risk when mortgage assets are securitized.  D... [More]

On November 24, 2010 the FDIC published FIL-81-2010, Overdraft Payment Programs and Consumer Protection, with the expectation that FDIC-supervised institutions will be in compliance with the guidance contained therein by July 1, 2011. While this fina... [More]

In our October 2008 newsletter, John Soffronoff and I highlighted that the burdens of liquidity risk management (e.g., new regulatory demands to monitor and report liquidity to the regulators) would rapidly rise up for many if not all of our clients ... [More]

Has your financial institution registered with the Nationwide Mortgage Licensing System and Registry (NMLSR) yet?  Have your residential mortgage loan originators (MLOs) registered yet?  The deadline for MLOs to register and to continue to ... [More]

Like my last newsletter article on internal monitoring programs, this article is based on an actual event which took place within the past month. As you read it, consider your current “Information Destruction Procedure.”   I happen... [More]