Regulatory Compliance Update July 2018

Regulatory Compliance Update

By: Hickman Beckner, Senior Vice President

I have reviewed the Compliance News for June 2018.  There have been updates to the CDIA Reporting Guide and the IRS has published changes for 2018 reporting forms.

The Consumer Data Industry Association has published updates to the Credit Reporting Resource Guide.  Field definitions have been updated and clarified.  The definition for the following fields were updated:

  • Base Segment; Field #21 (Current Balance) – the field description has been modified slightly to make it consistent with the guidance provided in Section 6 (Frequently Asked Questions & Answers). The changes are highlighted below in yellow.
  • Base Segment; Field #25 (FCRA Compliance/ Date Of First Delinquency) – the field description has been changed to clarify the importance of this field.
  • Exhibit 6 (Special Comment Codes) – the introductory paragraph has been added to be consistent with Exhibit 7.
  • Exhibit 9 (Explanation & Examples Of FCRA Compliance/DateOf First Delinquency) – The definition was clarified to indicate how the field is used.
  • Exhibit 11 (Consumer Information Indicators) – The definition of “Reaffirmation was clarified.

Frequently Asked Questions & Answers (Q&As) [Section 6] – Multiple answers were clarified and expanded.

Glossary Of Terms [Section 7]

The following glossary entries have been modified:

  • Reaffirmation Of Debt – the title has been modified to indicate that it only applies to Chapter 7 bankruptcy. The title now reads:

Reaffirmation of Debt (Bankruptcy Chapter 7)

  • Reaffirmation Of Debt Rescinded – the title has been modified to indicate that it only applies to Chapter 7 bankruptcy. The title now reads:

Reaffirmation of Debt Rescinded (Bankruptcy Chapter 7)

The IRS has published changes for forms produced for loan reporting.  Shaw Systems is currently updating our solutions for the changes.  The changes will be delivered in time for testing of 2018 IRS Reporting.  If you have any questions, please contact your account representative.  The following forms have been modified:

1042-S – Foreign Person’s U.S.  Source Income Subject to Withholding

1098 – Mortgage Interest Statement

1099-A – Acquisition or Abandonment of Secured Property

1099-C – Cancellation of Debt

1099-INT – Interest Income

Significant Dates:

July 1, 2018 – Effective date for Federal Reserve’s final changes to check collection and return procedures in Regulation CC.  The new regulations encourage banks to clear and return checks electronically.  This will make returned items (NSF checks) be returned sooner.

July 13, 2018 – Comments due on regulatory capital rules regarding the transition to Current Expected Credit Losses methodology for credit loss allowance.

July 30, 2018 – Comments due on IRS proposed changes on when information returns must be files electronically.

August 3, 2018 – Comments due on NCUA’s proposal to provide credit unions with additional options for payday alternative loans.

August 19, 2019 – Published Compliance date for CFPB’s final rule for payday loans.  This rule has been rescinded by Congress.

Emerging Legislation:

Congress has been in its summer recess and no new bills have been reported.

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