Regulatory Compliance Update October 2015

Regulatory Compliance Update

By: Hickman Beckner, Vice President

We’ve reviewed the Compliance News for September and October 2015. The month of September was a slow month for regulatory activity.

The Federal Financial Institutions Examination Council (FFIEC) has proposed changes to the Bank Call Reports.

Schedule RC-C Loans and Lease Financing Receivables

The reporting instructions have been clarified for Home Equity Lines of Credit (HELOCS). During the draw period HELOCS will be reported in the Revolving category. Once the HELOC has converted to repayment status, it will be reported in the Closed-End Loan category.

Memo Item 1 that accompanies RC-C has been modified to eliminate separate reporting for restructured loans to depository institutions, foreign governments, real estate in foreign offices and other loans.

Significant Dates:

October 1, 2015 – Effective date for final changes to flood insurance regulations.

November 2, 2015 – Comments due on FinCEN’s proposed rules to require certain registered investment advisors to implement formal anti-money laundering programs, file suspicious activity reports, file currency transaction reports and keep records relating to the transmittal of funds.

November 12, 2015 – Comments due on the IRS proposal to eliminate the automatic extension for filing W-2’s.

November 17, 2015 – Comments due on the FFIEC proposed changes to the Bank Call Report.

Emerging Issues

As part of the short-term highway funding bill passed by Congress and signed into law by President Obama, the IRS will be requiring additional information for mortgage interest reporting. The provision requires the reporting of the origination date of a mortgage, the property address for the collateral and outstanding balance on the loan at the beginning of the tax year. The new reporting elements go into effect for tax year 2017 so lenders and servicers don’t have to report the new data elements to the borrower and IRS until January 2018.

Shaw Systems is monitoring the new law and the rules the IRS will have to issue to implement the law.