fipco: your one-stop-shop for supplies and products · 1) don’t be too quick on that submission....
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1 | FIPCO FOCUS | FEBRUARY 2020
2013FEBRUARY 2020
To help promote efficiency and precision, FIPCO offers three interfaces that can transfer loan data from Compliance Concierge™ Loans and/or Mortgage directly to HMDA and/or CRA reporting solutions. As powerful tools for maximizing precision, interfaces work behind the scenes to provide direct and timely access to correct information, while streamlining productivity and reducing the potential for compliance errors. With HMDA/CRA reporting just around the corner, it’s time to take a closer look at FIPCO’s integration options from Compliance Concierge™ to QuestSoft Compliance Relief, HMDA Wiz and the FFIEC reporting tool. Contact [email protected] for more information or to schedule a free demo.
FIPCO: Your One-Stop-Shop for Supplies and Products
FIPCO’s most well-known products are the WBA forms and the software suite featuring them, Compliance Concierge™. However, we also offer a plethora of other essential financial institutions supplies and products, such as:
• Safety Paper• Notices• Envelopes• Counter Supplies
Brick-and-mortar bank branches cannot function without supplies like these for their front-line staff, whether they are personal bankers, tellers, or universal bankers. In addition to the listed products, FIPCO has a full range of front-line supplies covering everything from cash tickets to coin wrappers and currency straps.
For more information about FIPCO forms, software, or other products, visit www.fipco.com, call 800-722-3498 option 5, or email [email protected].
Okay, no one is really in love with HMDA, so referencing such a complex regulation in this fashion may not be the best analogy. However, small community banks have had it easy over the last couple of years when it comes to collecting data, reporting it on their Loan Application Register (LAR), and submitting it to CFPB. I'm afraid those times may soon be ending.
Much like the implementation of TRID, our regulators gave us an unofficial reprieve under the new HMDA data collection points and procedures as everyone tried to sort out the voluminous information, implement new software, and update internal process and procedures.
Regulators even went so far as to indicate which data points would rise to the level of scrutiny and which data points might get a pass if reported incorrectly.
As loan operation departments across the country begin to submit their 2019 LAR, here are a few points for consideration:
1) Don’t be too quick on that submission. LARs are not due until March 1, 2020. Too often a straggling mortgage loan gets lost inoverall processing. Loan operation personnel have been busy with property tax payments, 1098 IRS reporting, and in some casesannual mortgage statements. Rushing to submit your HMDA LAR could result in missed records. Take your time and be thorough.
2) Independently scrub your HMDA LAR with a risk-based focus. Banks that originate fewer than 500 mortgage loans in thepreceding year qualify for partial exemption of certain data points, yet their software may still be collecting all data points.Only focus on what you are required to report.
HMDA – Is the Honeymoon Over for Small Banks?
Integrations for Precision,
Efficiency.
BANKSUPPLIES
Jeff Schmid
(continued on p. 3)
2 | FIPCO FOCUS | FEBRUARY 2020
FEBRUARY 2020
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Nearly 50% of bank respondents who are currently not banking hemp said they will extend services to hemp-related customers in 2020 according to a recent Wisconsin Bankers Association (WBA) survey.
WBA’s annual Bank CEO Economic Conditions Survey asked three hemp-related questions in addition to more traditional economic inquiries. The responses highlighted that many Wisconsin banks have been working through the complex regulatory issue of hemp and are now better prepared to assist their customers.
Fortunately, FIPCO has developed a form that helps your bank ask the right questions and obtain the documentation needed to determine if your customer is complying with Wisconsin law. This form specifically provides a list of questions staff should be asking as well as a Certification that may provide your financial institution with additional comfort in banking these customers.
Contact [email protected] for more information!
Hemp Banking is Likely to Expand in 2020
By Scott Birrenkott
Q : Does the Taxpayer First Act Require Authorization Before Sharing Certain Tax Return Information?
A: Yes.
The Taxpayer First Act (Act) requires borrower authorization before tax return information can be shared. Specifically, Section 2202 of the Act provides that: “Persons designated by the taxpayer under this subsection to receive return information shall not use the information for any purpose other than the express purpose for which consent was granted and shall not disclose return information to any other person without the express permission of, or request by, the taxpayer.”
The Act does not provide further guidance on what constitutes “use” of the information. However, the Act does provide for significant penalties when information is used without consent. Thus, financial institutions that acquire such information will need to decide when to obtain consent before sharing or otherwise using tax return information for purposes other than that for which original consent was granted.
To support these changes, a form is available in both the origination and closing modules for FIPCO Compliance Concierge™ users. Nonusers should check with their forms provider to confirm whether a similar form will be provided. The applicable provision of the Act took effect on Dec. 28, 2019.
Scott Birrenkott is WBA assistant director – legal.
Note: The above information 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.
Wisconsin Bankers Association
Legal Q&ARemodel Update:
FORMS
The FIPCO remodel is progressing, meaning FIPCO staff have relocated to temporary workstations to accommodate the construction. Thirteen of us are in the FIPCO computer training room for the time being. We are looking forward to sharing our updated office with all of you this spring!
A Novel Idea!This month’s featured book is a recommendation from Annette Witkowski, Director – Training and Support. Annette is reading
“Extreme Ownership: How U.S. Navy SEALs Lead and Win” by Jocko Willink and Leif Babin.
FEBRUARY 2020
FEBRUARY 2020 | FIPCO FOCUS | 3
4721 South Biltmore Lane | Madison, WI 53718P: 800.722.3498 | [email protected]
3) Outsource, outsource, outsource – especially if your banklacks HMDA-trained personnel to scrub your LAR. Thispreventative cost will be less expensive than if you mustscrub and re-file past LARs. Not to mention that CMPsare still applicable to HMDA violations.
4) Look for missing records, especially commercial loanssecured by residential mortgages. These continue toevade our reporting as they don’t go through the normalmortgage loan processing channels. Using core systemreports to identify these loans and compare them againstyour LAR should be your first step.
5) Take advantage of technology going forward. Your LOSsystems can either interface or prepare your HMDA LARthese days. Find a vendor that compliments your internalprocess. Most errors occur when re-entry of the datapoints is necessary.
As a community banker that served our state and industry on the Small Entity Review Panel when CFPB was drafting the new HMDA regulation, I can appreciate the nuance and struggles banks are facing when trying to comply. If your bank needs assistance with your HMDA scrubs and/or implementing efficient and effective processes, please contact FIPCO’s ShareFI team at [email protected] or 608-441-1220. Happy reporting!
Jeff Schmid is Director – Compliance and Management Services for FIPCO®.
HMDA and Small Banks (continued from p. 1)
A new feature has been added to the FIPCO website to obtain copies of all Compliance Concierge™ Release Notes and Updates.
» To acquire a pdf copy of allCompliance Concierge™
Release Notes and Updates,go to www.fipco.com.
» Log onto the FIPCO website andclick on: Concierge Support—Software Updates & Notices —Releases & Updates.
» Next, under the heading ‘Compliance Concierge™ Releases& Updates,’ there is a link that includes all Release Notespertaining to Loan/Mortgage and/or Deposit, depending
on subscribed module access. Once the link is clicked, the pdf will appear in chronological date order and can be downloaded, saved, and searched with ease.
Support Corner with Chris and CathyLet us help – call us today at 800-722-3498.
Mark Your Calendars!FIPCO has several opportunities in the upcoming year to enhance your knowledge of Compliance Concierge™ and the newest regulatory changes.
The Spring Deposit Software and Compliance Forum will be held May 7, 2020 at the brand-new WBA/FIPCO Engagement Center. The Engagement Center will have two dedicated training rooms with the ability to hold 54 and 28 students, respectively. In addition, there will be a Board Room with video conferencing capabilities, and a conference room with a touchscreen smartboard.
The Loan/Mortgage Software and Compliance Forum will be held Nov. 18-19, 2020 in Wisconsin Dells.
Watch for spring 2020 Tour de CC webinar sessions this year! The short sessions are held over the course of one to two weeks. You pick the topic(s) that will assist you the most.
Visit the FIPCO website, or contact the FIPCO Training Department at (800) 722-3498, option 4, for complete details, pricing, and available webinar training sessions.