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ComplySight Newsletter

A Web-Based Compliance Management and Tracking Solution
November 2018

Vol. 5, No. 5

In this Issue:

Introduction

ComplySight Resources

ComplySight Training

Contact Us

Closing Comments from Glory

Introduction

Happy Holidays!!! Can’t believe we are almost done with 2018!

At the end of every year, we have the dollar amount changes for several thresholds in the BCFP rules, the Federal Reserve Board rules and even IRS rules. As a reminder, those thresholds (that we know of now) are listed below. However, in order to keep ComplySight accurate, they will not be updated until a few days prior to their actual effective date. So, there will be no vacations for us the last week of the year!

Regulation Z – Ability-to-Repay

As noted above, each year the BCFP is required to calculate the dollar amounts for several provisions within Regulation Z. The changes made to the points and fees thresholds within the Ability-to-Repay requirements are recalculated for inflation, using the Consumer Price Index for All Urban Consumers Index (CPI-U). In order to comply with these changes effective on January 1, 2019, the credit union must have points and fees below these new thresholds in order for the mortgage to be a “qualified mortgage” with the safe harbor protections.

  • 3 percent of the total loan amount for a loan greater than or equal to $107,747;
  • $3,232 for a loan greater than or equal to $64,648 but less than $107,747;
  • 5 percent of the total loan amount for a loan greater than or equal to $21,549 but less than $64,648;
  • $1,077 for a loan greater than or equal to $13,468 but less than $21,549; or
  • 8 percent of the total loan amount for a loan less than $13,468.

Regulation Z – High Cost Mortgage

Similar to the changes made above under the Ability-to-Repay rules, the BCFP also amended the points and fees thresholds for determining whether a loan is considered a “high cost mortgage” and therefore subject to the relevant protections under the applicable rules. These changes also become effective on January 1, 2019.

A covered loan will be considered a high-cost mortgage if the points and fees exceed the following thresholds:

  • 5 percent of the total loan amount for a loan amount greater than or equal to $21,549;
  • 8 percent of the total loan amount or $1,077 (whichever is less) for a loan amount less than $21,549.

Regulation Z – Higher-Priced Mortgage Loan Escrow Exemption and Small Creditor Exemption for Portfolio and Balloon Payment Qualified Mortgages.

The BCFP adjusts their asset-size threshold for credit unions to qualify for an exemption to the escrow account requirements for higher-priced mortgages. The same asset-size threshold will also determine eligibility for small-creditor portfolio and balloon-payment qualified mortgages. Therefore credit unions with assets below a certain amount (among a few other criteria) may be exempt from the HPML escrow requirements and also eligible for small creditor status. This adjustment has not yet been published.

Regulation Z – Higher-Priced Mortgage Loan Appraisal Exemption

The BCFP exempts certain higher-priced mortgage loans (HPMLs) from the appraisal requirements if they are below an amount that is adjusted each year for inflation. Effective January 1, 2019, HPMLs that are less than $26,700 will not be required to have an appraisal under the rules.

Regulation Z – Credit Cards

Credit unions should be aware that the safe harbor penalty fees for credit cards under Regulation Z that have been updated, are effective on January 1, 2019 and are listed below:

  • $28 for the first late payment fee; and
  • $39 for each subsequent violation within the following six months.

Regulation C - HMDA

Each year the BCFP evaluates the asset-size exemption under HMDA as compared with the Consumer Price Index for Urban Wage Earners and Clerical Workers (CPI-W). We don’t yet have the asset-size threshold adjustment for 2019.

Regulation D – Reserve Requirements

Each year, the Federal Reserve Board makes adjustments to the reserve thresholds within Regulation D using statutory formulas specified in the Federal Reserve Act. Credit unions must maintain reserves based on the mix of deposits. Below are the thresholds for 2019:

  • The first $16.3 million is exempt from the reserve requirement;
  • Transaction accounts between $16.3 million and $124.2 million will have a 3 percent reserve requirement; and
  • Transaction accounts over $124.2 million will have a 10 percent reserve for amounts over $124.2 million plus $3.237 million.

IRS Rules – Health Savings Accounts

Credit unions should be aware of the change in contribution limits to health savings accounts for both individuals and families effective on January 1, 2019:

Contributions must be no more than $3,500 in 2019 for an individual health plan or $7,000 in 2019 for a family health plan. These figures are adjusted annually, based on cost of living increases. Members over the age of 55 may make an additional “catch-up” contribution of $1,000.

Regulation M – Consumer Leasing

Certain requirements exist for credit unions offering consumer leases. Under Regulation M, a consumer lease is defined and includes a total contractual obligation that cannot be exceed, which is adjusted annually. Effective January 1, 2019, that lease amount is $57,200.

 

ComplySight Resources

ComplySight Resources

Yep, we have even more exiting changes to announce!

Grading Screen Updates

The Grading Screen has been updated to provide more information and added functionality.

  • We have added the employee assignment information
  • We are now showing the status of grading the Factor (ungraded, active or complete)
  • L2 Users can now mark the Factor as Complete (or Incomplete) from the Factor Grading Screen
  • Any active AAI/MAI/EAFs are indicated with an interactive button which allows the user to go directly to the item (or a filtered list, if more than one active item exists)
Grading Screen updates

New Option to Move Compliance Officer Comments made on an Automatic Action Item to the Grading Screen

When a Factor is graded below threshold and the Automatic Action Item (AAI) is created, there is an option for any Compliance Officer comments on the Grading Screen to be added to the AAI. Many clients will add additional Compliance Officer comments to the AAI as they work through the process of resolving the issue. Previously, those new comments were only available in the AAI. Now, when the AAI is resolved, the user has the option to move any new Compliance Officer comments made on the AAI back to the grading screen so that all comments related to that Factor grade are captured in one spot.

Moving Comments

Remove Inactive Users from Default View

When a user is de-activated from the system, their user information is not removed so that any history (grading, comments, etc.) made by that user is retained. However, over time as staff and responsibilities change, many clients were finding that their “Manage Employee” area was becoming difficult to manage due to the number of inactive users.

We have added a filter in the “Employee Management” area to allow clients to view Active Users only, Inactive Users only, or All Users. The default view is Active Users only.

Removing Inactive Users

Copy Staff on Compliance Questions

When sending in a compliance question using the form within InfoSight, users can now copy other staff members (any active user within the system) on that question.

Copy Staff

Action Items and Examiner Audit Finding Email Updates

The system generated emails for Automatic and Manual Action Item and Examiner Audit Finding notices have now been updated to include a direct link to that item. This should make reviewing these items a much easier process! It’s important to note that when using these links, you must be logged into the correct access level. For instance, these items are not available to L1, or L4 users, and they are not available to users logged into the Complaint System. Also, if an item has been included as part of an Export, the link that was generated on any email previous to that export will no longer be valid. This would likely be a rare case, but it is important to note.

Email Updates

Also, in the case of an update to the item (change in subject, persons assigned, assignment date, etc), the email will now provide details of what changed.

Employee Compliance Assignment Email Updates

The system-generated emails for Employee Compliance Assignment notices have now been updated to include a direct link to that Item listing (for Area assignments) or the Factor listing (for Item assignment). This should make compliance reviews a much easier process!

Email Updates

ComplySight
Training

ComplySight Training

VIDEO TUTORIALS – Log in to ComplySight and click on the “Training and Support” page to access video training tutorials to make your ComplySight experience even better! These are also available 24/7!

Contact Us

Technical questions (software operation issues) can be submitted through the Technical Support form in ComplySight

Compliance related questions can be submitted through the Compliance Questions form in ComplySight.

For other questions: click here

Closing Comments from Glory

For those of you going through the budgeting process, we are happy to report that once again there is not going to be an increase in pricing for ComplySight licensing fees in 2019! YAY!! We are extremely thankful to our League/Association owners and partners to allow us to continue to provide you access to ComplySight at an exceptional value.

“ComplySight doesn’t cost very much, how can it provide credit unions with any value?” Yes, we’ve heard that and we need your help in dispelling that rumor! Just because something is expensive, doesn’t mean it’s valuable…..I think we can all agree on that.

Speaking of value, we really hope you are all able to start to utilize the Complaint Management System we added to ComplySight (at no additional cost). With ComplySight, credit unions have access to an easy-to-use Compliance Management System and Complaint Management System for a fraction of the cost of what is out there in the market, for just ONE of those modules!

Please remember that we love your feedback! Don’t forget to drop us a quick note! Let us know your thoughts for improvement or let us know how ComplySight has helped your credit union. We love hearing it all and are so thankful for your continued support!

Happiest of Holidays to you all!

Glory

Glory LeDu, CUCE, BSACS, CUERME

Glory.LeDu@cusolutionsgroup.com

ComplySight is a product of League InfoSight, CUNA and your State Association or League.

Make sure your credit union is taking advantage of InfoSight and CU PolicyPro, League InfoSight’s other compliance products!