All in Regulatory Update

CFPB Issues Final Rule for Payday & Vehicle Title Loans

Adam Witmer
Regulation Z, Regulatory Update

On June 7, 2019, the CFPB issued a final rule to delay the August 19, 2019 compliance date for the mandatory underwriting provisions of the previously issued 2017 final rule on Payday, Vehicle Title, and Certain High-Cost Installment Loans. Compliance with the provisions of the 2017 rule is now delayed by 15 months, to November 19, 2020, so that the CFPB has sufficient time to re-evaluate this rule based on their proposal to reconsider the rule a few months ago. The Bureau is also…

Congress Extends Flood Insurance Program for Twelfth Time

Adam Witmer
Flood, Regulatory Update

On June 3, 2019, Congress extended the National Flood Insurance Program for another four months, through the end of September, 2019. This marks the twelfth temporary extension of the flood program within the last two years. As we have noted before, this large number of temporary extensions signal a desire by Congress to make long-term changes to the program. This, of course, should be an advance notice to compliance professionals that future changes with flood insurance rules are highly probable.

OFAC Announces Framework for Compliance

Adam Witmer
BSA, Regulatory Update

On May 2, 2019, OFAC released a document titled A Framework for OFAC Compliance Commitments in order to provide organizations subject to U.S. jurisdiction, as well as foreign entities that conduct business in or with the United States or U.S. persons, or that use U.S.-origin goods or services, with a framework on the essential components of a sanctions compliance program.  The document also…

Congress Extends Flood Program

Adam Witmer
Flood, Regulatory Update

For the eleventh time since 2017, Congress extended the National Flood Insurance Program on May 30/2019 by another two weeks. The flood Program, which was set to expire on June 1, is now extended through June 14, 2019 meaning that new flood insurance policies can be issued and real estate transactions won’t be delayed during this time. This two week extension provides

CFPB Releases Spring 2019 Rulemaking Agenda

Adam Witmer
Regulatory Update

On May 22, 2019, the CFPB released their Spring 2019 rulemaking agenda.  This semi-annual report provides a list of regulatory matters that the CFPB anticipates having under consideration for the next year.  The Spring 2019 Agenda is broken down into three different sections including implementing statutory directives, the continuation of other rulemakings, and new projects and further planning.

The following rules are listed…

FinCEN Announces Law Enforcement Awards

Adam Witmer
BSA, Regulatory Update

On May 16, 2019, FinCEn hosted their fifth annual “Law Enforcement Awards” program which recognizes law enforcement efforts that utilize BSA reporting in criminal investigations and prosecution.  The seven award categories include significant fraud, cyber threats, SAR review team, state and local law enforcement, third party money launderers, transnational organized crime, and transnational security threats.  In their release, FinCEN describes each applicable case, which provides insight into various money laundering activity occurring in the United States.

FinCEN Provides Guidance on Convertible Virtual Securities

Adam Witmer
Regulatory Update, BSA

On May 9, 2019, FinCEN issued two different pieces of guidance relating to virtual currency.  The first issuance is guidance titled “Application of FinCEN’s Regulations to Certain Business Models Involving Convertible Virtual Currencies,” also known as FIN-2019-G001.  The second issuance was an Advisory (FIN-2019-A003) on Illicit Activity Involving Convertible Virtual Currency.  

CFPB Proposes Debt Collection Regulations

Adam Witmer
Regulatory Update

On May 7, 2019, the CFPB released a Notice of Proposed Rulemaking to implement the Fair Debt Collection Practices Act.  This long-planned proposal would provide consumers with a number of protections such as restrictions against harassment by debt collectors as well as clear options to dispute debts.  The proposed rule would also establish “bright-line” limits that creditors must follow regarding the number of calls they can make to consumers.

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