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Common Sense Compliance

Lucy and Nancy seek common sense amid the bewildering compliance world. Each blog delves for meanings behind trends—and missed footnotes that mean a big deal.

"Stop!" is clear enough, but when the subject is UDAAP, often much isn't so clear.
Common Sense Compliance

UDAAP? Violation? Or both?

Written by | 03/29/2018 - 14:23 |
Comments:   DISQUS_COMMENTS
Ten years after Dodd-Frank added the extra “A,” it's still a mystery
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How will Acting CFPB Director Mick Mulvaney treat the bureau's complaints program? He's looking for input from banks and other stakeholders.
Common Sense Compliance

Any beefs about CFPB complaint system?

Written by | 03/01/2018 - 15:35 |
Comments:   DISQUS_COMMENTS
Bureau seeks input as part of overall review
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If your bank doesn't go after root causes, regulators may oblige. The fault may ultimately lie in your bank's compliance management system.
Common Sense Compliance

“Why?” is the spade of root cause analysis

Written by | 02/06/2018 - 22:02 |
Comments:   DISQUS_COMMENTS
Obvious causes aren’t always the answer. You have to dig
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Death for GFE and HUD-1 docs highly exaggerated
Common Sense Compliance

Death for GFE and HUD-1 docs highly exaggerated

Written by | 01/19/2018 - 19:47 |
Comments:   DISQUS_COMMENTS
Quick compliance tip on key reg
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Richard Cordray will be leaving CFPB by the end of November. Nancy Derr-Castiglione examines how the Consumer Financial Protection Bureau developed and how she thinks it ought to change.
Common Sense Compliance

Looking on as Cordray steps down

Written by | 11/16/2017 - 01:38 |
Comments:   DISQUS_COMMENTS
Compliance veteran gives her wish list
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Regulators periodically publish their estimates of how long it takes to comply with information collection requirements. Nancy Derr-Castiglione does a bit of math, for the "fun" of it.
Common Sense Compliance

Checking out regulatory math

Written by | 09/06/2017 - 20:05 |
Comments:   DISQUS_COMMENTS
How close do regulators come on compliance time burden?
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Is climate change risk on your bank’s radar?
Common Sense Compliance

Is climate change risk on your bank’s radar?

Written by | 07/17/2017 - 13:01 |
Comments:   DISQUS_COMMENTS
International group finalizes voluntary measures banks can take
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Letter from Colorado: banks and the marijuana business
Common Sense Compliance

Letter from Colorado: banks and the marijuana business

Written by | 05/12/2017 - 11:40 |
Comments:   DISQUS_COMMENTS
Recreational drug firms finding easier access to financial services
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Compliance expert Lucy Griffin warns that pendulums swing both ways, and bankers who count on permanent change forget that at their peril.
Common Sense Compliance

Regulatory relief: When the pendulum swings ...

Written by | 02/23/2017 - 20:51 |
Comments:   DISQUS_COMMENTS
… be careful or it will smack you when it swings back
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Latest guidance on third-party relationships continues growing and widening stress on vendor management by federal regulators.
Common Sense Compliance

Third-party scrutiny expands at OCC

Written by | 02/13/2017 - 14:54 |
Comments:   DISQUS_COMMENTS
Customer complaints play a growing role in exam scrutiny
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