Independent Banker - June 2017 - 68

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months from now. On Jan. 1, 2019,
Appendix A, which provides instructions
for completing and submitting
the HMDA loan application register
(LAR), is removed from Regulation C,
and covered institutions will report
the new dataset required by the
HMDA Rule, using a new electronic
submission tool and revised procedures
that will be available from the
CFPB. Beginning in 2020, the HMDA
Rule requires quarterly reporting for
covered institutions that reported
a combined total of at least 60,000
applications and covered loans in the
preceding calendar year.
Compliance game plan
A simple evaluation process can be
applied to these and other regulatory
announcements. The evaluation
should include products and services
currently offered by the bank
directly and those offered through
or administered by a third party. As a
prudent practice, keep a record of the
analyses and results.
1. Read each rule as soon as it is practical
to understand the incumbent
requirements.
2. Determine if the rule applies to
your bank.
3. If the rule applies to your bank:
» Confi rm the effective date(s)
and the specifi c requirements
for each. Monitor for subsequent
modifi cation.
» Identify key stakeholders,
and determine which systems,
procedures, and records may be
affected.
» Facilitate the changes to functional
areas.
» Update the compliance
management system (CMS), and
ensure follow-up reviews, monitoring
and auditing are included in
the support processes.
4. If the rule doesn't currently apply
to your bank but could in the
future (for instance, if the rule
applies to banks, but your bank is
not offering a covered product),
schedule a relook on a periodic
basis to monitor changes to your
bank, its products or services or its
third-party vendors.
Community banks can continue to
effectively analyze and implement
the variables in the regulatory landscape
by watching the road before
them while keeping a sharp eye on
the horizon.
Mary Thorson Wright is a former
Federal Reserve examiner and a writer
in Virginia.
ICBA Corporate Member Solutions:
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Independent Banker - June 2017

Table of Contents for the Digital Edition of Independent Banker - June 2017

Table of Contents
Independent Banker - June 2017 - Intro
Independent Banker - June 2017 - Cover1
Independent Banker - June 2017 - Cover2
Independent Banker - June 2017 - Table of Contents
Independent Banker - June 2017 - 2
Independent Banker - June 2017 - 3
Independent Banker - June 2017 - 4
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Independent Banker - June 2017 - Cover3
Independent Banker - June 2017 - Cover4
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https://www.nxtbook.com/mspc/independentbanker/october2021
https://www.nxtbook.com/mspc/independentbanker/september2021
https://www.nxtbook.com/mspc/independentbanker/august2021
https://www.nxtbook.com/mspc/independentbanker/july2021
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https://www.nxtbook.com/mspc/independentbanker/may2021
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https://www.nxtbook.com/mspc/independentbanker/february2021
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https://www.nxtbook.com/mspc/independentbanker/february2018
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https://www.nxtbook.com/mspc/independentbanker/november2017
https://www.nxtbook.com/mspc/independentbanker/october2017
https://www.nxtbook.com/mspc/independentbanker/september2017
https://www.nxtbook.com/mspc/independentbanker/august2017
https://www.nxtbook.com/mspc/independentbanker/july2017
https://www.nxtbook.com/mspc/independentbanker/june2017
https://www.nxtbook.com/mspc/independentbanker/may2017
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