On August 21, 2019, the Financial Crimes Enforcement Network (FinCEN) issued an advisory (FIN-2019-A006) to alert financial institutions to possible schemes related to the trafficking of fentanyl and other synthetic opioids.  FinCEN explains that this new advisory will assist financial institutions in detecting and reporting suspicious activity, ultimately making it harder and more costly for criminals to (i) commit crimes related to the trafficking of synthetic opioids; (ii) hide and use their illicit money; and (iii) continue fueling the opioid epidemic that is currently occurring in the United States. 

Fin-2019-A006 highlights the

On 8/19/19, the NCUA issued guidance for federally insured credit unions on how they can serve lawfully operating hemp businesses.  As the 2018 Farm Bill made a number of changes to how hemp is treated under federal law, some credit unions have lawfully operating hemp businesses within their fields of membership.  The NCUA explains that credit unions may provide the customary range of financial services for business accounts, including loans, to lawfully operating hemp related businesses within their fields of membership.

In the guidance, the NCUA explains that

Our newest Compliance Class, UDAAP Foundations, is on sale now through August 31. This comprehensive UDAAP class runs nearly 3 hours and provides you with everything you need to know regarding one of the highest-risk areas of regulatory compliance - Unfair, Deceptive, and Abusive Acts and Practices. While the program covers the core elements of UDAAP, the best thing about this program may be in Part II of the program where we review over 50 known UDAAP violations! For more information on this program - and to take advantage of the Early Bird discount on this new program - go to www.compliancecohort.com/udaap-foundations.

As we explained before, Fannie Mae & Freddie Mac (the GSEs) announced in June 2019 that the optional use period for the new version of the Uniform Residential Loan Application (URLA) and automated underwriting system (AUS) implementations would be postponed. In a more recent release, the GSEs explained that they have now been directed to make specific modifications to the redesigned URLA, which is going to delay the February 1, 2020 implementation date. The following changes will be made to the redesigned URLA:

Our newest Compliance Class, UDAAP Foundations, will be released within the next week or so. We have finished recording the videos (nearly 3 hours!) and are now in the process of editing, uploading, and dealing with all the back-end work that goes into creating a video course. ;-). This course is a comprehensive overview of UDAAP rules and does something we believe is essential to mitigate UDAAP risk in your organization - we review over 50 known UDAAP violations. Yep, we believe that one of the best ways to mitigate UDAAP risk is to compare known UDAAP violations with the practices at your organization, so we have designed this course to provide you with a checklist to do just that. Part II of our program spends over an hour and a half discussing over 50 known UDAAP violations that have been identified by the regulators at other financial institutions. And just like all of our programs, UDAAP Foundations will have an Early Bird discount when we launch it within the next week or so. To have a sneak preview of what will be included in this course, take a look here: www.compliancecohort.com/udaap-foundations

The CFPB has again updated the TRID FAQs on their website. This update incorporates five new questions and answers relating to providing loan estimates to consumers. As has been the case with the previously released FAQs, these five new questions don’t really tell us anything we didn’t already know. That said, we will be including a review of these FAQs in our 3Q 2019 Quarterly Compliance Update program (planned to be released sometime in October 2019.