Compliance Blog

Posted by Anthony Demangone

The OTS has issued a "CEO's Letter" on the upcoming changes to RESPA.  Access it here.  The letter does a great job of providing a 20,000 foot overview of the changes.  Perfect for, say...a CEO.  Hence the name.  But the letter also notes that the OTS is furiously typing away on revisions to its RESPA examination procedures.  But it is doing so on an "interagency basis."  In other words, NCUA probably is working on the same project.  The OTS has updated a portion of the procedures already - the portion that addresses the parts of RESPA that took effect back in January.  The rest will follow later.  So keep an eye out for that document.  Exam procedures are like getting the grading key before the test.  In a word: useful.  In two words: very useful. 

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The Fed has issued additional guidance concerning its check processing centralization process.  Yesterday, the Fed announced that the Federal Reserve Bank of Cleveland will handle all paper check adjustments, effective October 1, 2009.  That's in less than 30 days. (Thanks for the heads up, guys.) Read all about it here.

I've stated this before, and I'll say it again.  The Fed at some point will have to re-tool Regulation CC.  All checks eventually are going to be local, as the plan is to have 1 check processing center. The local/non-local distinction is getting blurry.

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Have a great weekend, everyone.  I am on my way to Buffalo, NY today to attend the wedding of a very good friend.  And guess what just happens to be taking place this weekend in Buffalo?  The Buffalo Chicken Wing Festival.   Vegas has the over-under weight gain for me around 7.5 lbs.  I'm taking the "over." NAFCU is closed on Monday, so the blog will check back with you on Tuesday.