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WBA Compliance Center

The WBA Compliance Center is designed to highlight the services your bank can use to stay on top of the various compliance issues you will soon be facing.

The recently passed federal financial regulatory reform bill (Dodd-Frank Wall Street Reform and Consumer Protection Act) will deeply affect the future of the banking industry in Wisconsin. It has been conservatively estimated that the Dodd-Frank bill will generate 5,000 pages of new rules. Banks will be subject to at least 30 new or expanded regulations as a result of the enactment of the most sweeping rewrite of banking laws since the Great Depression. This will add to banks’ already high compliance costs and limit revenue opportunities.

Let WBA help you. Use the resources listed on this page to keep your compliance issues under control.

 

 

To help members avoid social media missteps, WBA now has a Model Social Media policy available for purchase by member banks. The policy, drafted by the WBA Legal Department, includes instructions and options enabling you to customize the policy to your institution’s unique needs. It is delivered electronically via the Internet, so you can quickly review and customize the text. The policy also incorporates the latest developments and opinions from the National Labor Relations Board (NLRB).

Order the WBA Model Social Media Policy

  

Latest Compliance News
FTC requests comment on Safeguards Rule standards
Aug. 30, 2016
The FTC is requesting public comment on its Standards for Safeguarding Consumer information. The 2003 Rule requires financial...
FRFS posts info on same-day ACH
Aug. 30, 2016
Federal Reserve Financial Services has posted a notice concerning how FedACH will deliver non-future-dated return items beginning with...
FDIC updates national rates
Aug. 30, 2016
The FDIC has updated its weekly national rates and rate caps.
FHFA extends HARP, adds refinance option
Aug. 26, 2016
The FHFA has announced that Fannie Mae and Freddie Mac will implement a new refinance option aimed at borrowers with high loan-to-value...
New FHA procedures to help homeowners avoid foreclosure
Aug. 26, 2016
HUD has announced new Federal Housing Administration procedures to strengthen the process mortgage servicers use to help struggling...
DoD issues guidance on MLA changes
Aug. 26, 2016
The Department of Defense has published an FAQ on its Military Lending Act regulation.
Read more in the archive
  
CFPB Issues Final Mortgage Rules

CFPB issues updated final mortgage rule for rural and underserved areas

The CFPB has finalized several changes to its mortgage rules to facilitate responsible lending by small creditors, particularly in rural and underserved areas. The final rule will be effective Jan. 1, 2016. View final rule

The new rule, which was proposed in January, will increase the number of financial institutions able to offer certain types of mortgages in rural and underserved areas, and gives small creditors time to adjust their business practices to comply with the rules. The final rule will:

  • Expand the definition of "small creditor": The loan origination limit for small-creditor status will be raised from 500 first-lien mortgage loans to 2,000 and will exclude loans held in portfolio by the creditor and its affiliates.
  • Include mortgage affiliates in calculation of small-creditor status: The final rule does not change the current asset limit for small-creditor status, which is set at less than $2 billion (adjusted annually) in total assets as of the end of the preceding calendar year. However, under the new rule the assets of the creditor's mortgage-originating affiliates are included in calculating whether a creditor is under the limit.
  • Expand the definition of "rural" areas: In addition to counties that are considered to be "rural" under the CFPB's current mortgage rules, today's final rule expands the definition of "rural" to include census blocks that are not in an urban area as defined by the Census Bureau.
  • Provide grace periods for small creditor and rural or underserved creditor status: Creditors that exceed the origination limit or asset-size limit in the preceding calendar year will be allowed to operate, in certain circumstances, as a small creditor with respect to mortgage transactions with applications received prior to April 1 of the current calendar year. The final rule creates a similar grace period for creditors that no longer operated predominantly in rural or underserved areas during the preceding calendar year.
  • Create a one-year qualifying period for rural or underserved creditor status: The final rule adjusts the time period used in determining whether a creditor is operating predominately in rural or underserved areas, from any of the three preceding calendar years to the preceding calendar year.
  • Provide additional implementation time for small creditors: Eligible small creditors are currently able to make balloon-payment Qualified Mortgages and balloon-payment high-cost mortgages regardless of where they operate, under a temporary exemption scheduled to expire on January 10, 2016. The final rule extends the sunset of that provision to cover balloon-payment mortgage transactions with applications received before April 1, 2016, giving creditors more time to understand how any changes will affect their status, and to adjust their business practices.
  
WBA Model Policy Library for Corporate Governance

Introducing the WBA Model Policy Library for Corporate Governance! Here your bank is able to purchase a single policy or charter or can mix and match a variety. Click here for more information and a complete list of the materials developed for this resource.

  
TILA/RESPA Resources

TILA/RESPA Resources to help you implement the new disclosures:

  
WBA Best Practices Library

WBA’s Best Practices Library is now open with over 75 resources including model forms, affidavits and even sample presentations for use in speeches! WBA's banker-driven committees have developed a variety of best practices for the use of WBA's members. Access this virtual library of free resources at www.wisbank.com/BestPractices.

  
Compliance Toolkits

As part of an ongoing effort to assist members with compliance efforts, WBA is adding a variety of compliance toolkits to its collection.

The latest is the WBA Third-Party Securities Networking Relationships Toollkit. Available free of charge, this toolkit, created by the Boardman Law Firm, details what bankers should know about broker-dealers providing services on bank premises.

Download any the kits below by clicking here.

WBA Third-Party Securities Networking Relationships Toolkit

WBA Executive & Incentive Compensation Toolkit

WBA FDIC Insurance Changes for Noninterest-bearing Transaction Accounts Toolkit

WBA SAFE Act Toolkit

WBA Dodd-Frank Toolkit

  
ABA Dodd-Frank Tracker

This regulatory reform calendar provided by the American Bankers Association organizes content into three categories: comment letter deadlines; effective and implementation dates; and hearings and meetings.

View calendar

  
WBA Compliance Journal

The WBA Compliance Journal is intended to provide accurate information in regard to the subject matter covered as of the date of publication; however, the information does not constitute legal advice. Click to read a preview of the latest issue of the WBA Compliance Journal.

  
Legal Q&A

The information provided in these articles is not intended to provide legal advice; rather, it is intended to provide general information about banking issues. Consult your institution’s attorney for special legal advice or assistance. Read Legal Q&A articles.

  
WBA Models

Model Pandemic Influenza Plan available
(Updated June 2009 with information on the H1N1 flu virus, and more)
Given the need for financial institutions to create a plan, WBA has prepared a model pandemic influenza plan for WBA members. The model is designed to be used on its own or as part of an institution's broader disaster recovery plan. Since the plan is intended as a model only, it must be customized by each financial institution to their specific situation prior to its implementation and use. Download the model here.

  
Education Opportunities
  
WBA Forms

WBA forms offered by FIPCO have been accepted as standard by bank regulatory agencies, attorneys and the Wisconsin judiciary. In conjunction with legal counsel, these forms are developed and reviewed and constantly updated by the WBA Drafting Team, helping to ensure compliance with State and Federal regulations.

 

Electronic Forms
Electronic files of commonly used WBA forms are available in various formats. These WBA form images are available using Microsoft® Word, Adobe Reader or other third party software systems. The images, or eForms, can be electronically filled out and printed.

WBA Hard Copy Forms
Over 430 forms relating to consumer, real estate, commercial, agricultural and municipal loans; deposit accounts; safe deposit boxes; and deposit and operations are available. Forms are purchased by financial institutions, dealerships, attorneys and realtors.

More information is available here. For more information contact FIPCO Sales.

  
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