Have you ever had the thought about leading a training session or moderating a panel of experts on a top or even a roundtable session of your peers? I have had the pleasure to host multiple webinars, a panel of experts and even multiple compliance roundtable sessions. I have had many people contact me about how I know so much [useless] information on so many different topics. The best response I have is that I like to read enforcement actions and try to understand what may have happened and what I may need to do to prevent my organization from being in the same situation as the party(ies) in the enforcement action.
Over the past few weeks, I have been working with Robin Cooper, CRCM, with Compliance Resources, on a new webinar that will take place on Wednesday, September 16th, titled, “Deposit Compliance Hot Topics, Recent Enforcement Actions, and Common Violations." I was very surprised by the number of deposit-related enforcement actions that have been issued by the regulatory agencies over the past two years. Many compliance professionals would consider the deposit-related regulations to be much less complicated yet the regulatory relief provided over the past six months included changes to the Expedited Funds Availability Act (implemented by Regulation CC) and the Federal Reserve Act (implemented by Regulation D) which may have an impact on your financial institutions.
Has your financial institution conducted a post-implementation review of the changes to the funds availability for a case-by-case hold under Regulation CC from $200 to $225? What about the increase in the amount of the large deposit exception hold funds availability from $5,000 to $5,525?
Did your financial institution make any changes related to the elimination of the six-transaction limit for an account previously classified as a savings deposit account? Did the financial institution change its disclosures, including the fee schedule? Were there reporting changes made related to reporting deposit accounts to the Federal Reserve?
These are just a few of the deposit-related rules and regulations that Robin and I plan to address during the webinar. If you are interested in attending, you still have time to register. If your financial institution is a Compliance Masters Group (CMG) member, there will be a shorter version of the presentation in the coming weeks. And if you decide not to participate, please know this stuff is not rocket science. The materials came from the content of enforcement actions published by the Federal agencies (FDIC, OCC, FRB, CFPB), as well as feedback from peers within the industry shared during expert panels and roundtable sessions (I.e., iron sharpening iron).
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