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Kicking off 2023!

As we do every January, we look at the New Year with a fresh set of eyes and start strategizing about managing new goals. 

In starting our new journey into 2023, it’s an important time to pause (for a moment at least), and take stock of what we accomplished in the last year. This is the perfect time to review those 2022 goals and make sure nothing slipped through the cracks. Ask yourself…Did I fulfill what I needed to? Did I miss anything? If so, you can take steps now to tighten up any loose ends. Next, you can turn your attention to 2023. As you know, our Online Compliance Consulting practice has always considered planning and strategizing as key components in successfully tackling the countless responsibilities that those in the compliance industry face.

With that in mind, it is particularly important to take a look at your Compliance Management System (CMS) and make any adjustments needed to strengthen it and make it more robust. Also, you’ll want to ensure you start the year off on the right foot and be cognizant of what’s already on the calendar.

To assist in this process, SC+S has developed a bundle of checklists. 

First, we have a set of 2023 Compliance Program Checklists that provides more specific and detailed steps you can take in strengthening your program. This valuable resource incorporates checklists for the new year, including a list of compliance Items that should already be on your 2023 calendar, as well as policy reviews, compliance reviews (internal and external), and compliance training.   

Second, we also have a new workbook dedicated to UDAAP Considerations. The information provided therein may be used as part of an institution’s considerations of any act or practice, existing or proposed, as to whether it could be construed as unfair, deceptive, or abusive.

Third, we also have a Compliance Management System workbook that contains various checklists that will help you focus on important aspects of your CMS. While it is a higher-level resource, it outlines important considerations and focuses attention on CMS-related issues, such as board and management oversight, as well as critical program components such as implementation of controls and involvement in change management. 

Our clients can find these resources in the Online Compliance portal’s Knowledge Base, within the SC+S Tools, Checklists, and Guides folder.

Happy New Year from Sheshunoff Consulting + Solutions!

2023 New Year Thresholds and Adjustments

With every New Year, Compliance Officers are familiar with new regulatory issuances that address adjusted thresholds. These issuances help us determine the applicability of a variety of compliance issues. 

If you haven’t already reviewed these recent issuances, now is the time to do so. Besides impacting processes, this type of information is also often referenced within internal policies. 

Here is a recap of recently effective issuances:

• Reg C / HMDA - Adjustment to Asset-Size Exemption Threshold - eff 1/1/2023
• Reg M / Consumer Leasing - Adjustment to Exemption Threshold - eff 1/1/2023
• Reg Z / TILA - Adjustment to Exemption Threshold - eff 1/1/2023
• Reg Z / TILA - Adjustment to Asset-Size Exemption Threshold - eff 1/1/2023
• Reg Z / TILA - Adjustments for Credit Cards, HOEPA, and QMs - eff 1/1/2023
• Reg Z / TILA - Appraisals for HPMLs Exemption Threshold - eff 1/1/2023

Our clients can find greater details on these issuances in the Online Compliance portal’s Knowledge Base, within the Compliance Alerts folder.

Just last month, the CFPB amended their brochure, “What You Should Know About Equity Lines of Credit” and uploaded it to their website. This brochure is tied to Reg. Z provisions, under 12 CFR 1026.40(e), that require it be provided to consumers applying for a HELOC.

We have received questions about whether the immediate use of the updated brochure is required. Fortunately, the CFPB has addressed this, as follows:

“Creditors may, at their option, immediately begin using the revised HELOC brochure, or a suitable substitute, to comply with the requirements under 12 CFR 1026.40(e). The Bureau understands, however, that some may wish to use their existing stock of the HELOC brochure. Therefore, those who provide this publication may use earlier versions of the HELOC brochure until existing supplies are exhausted. When reprinting the HELOC brochure, the most recent version should be used.”

Interested persons may find the CFPB’s announcement here and the updated brochure of the CFPB’s website here.