All in Regulatory Update

CFPB Cracks Down on Student Debt Relief Operation

Adam Witmer
Regulatory Update

On 10/30/19, the CFPB announced an action to halt a student-loan debt-relief operation engaged in allegedly unlawful conduct and consisting of several related companies. The Bureau alleges that since at least 2015, the debt-relief companies operated as a common enterprise and deceived thousands of federal-student-loan borrowers and charged over $71 million in unlawful advance fees in connection with the marketing and sale of student-loan debt-relief services to consumers.  

As described in the complaint, the Bureau alleges that…

USDA Issues HEMP Guidance

Adam Witmer
Regulatory Update, BSA

On 10/29/19, the USDA released a long-awaited interim final rule relating to the growing of industrial hemp. This program, as required by the 2018 Farm Bill, will establish a consistent regulatory framework around hemp production throughout the United States. As explained in their release, the USDA rule includes provisions for…

CFPB Announces Symposium on Small Business Data Collection

Adam Witmer
Regulatory Update

On October 24, 2019, the CFPB announced its third symposium in a series that started earlier in 2019. The most recent discussion will focus on Section 1071 of the Dodd Frank Act, which amends the Equal Credit Opportunity Act (ECOA) to require financial institutions to collect, report, and make public certain information concerning credit applications made by women-owned, minority-owned, and small businesses.

As has been the case with the other two symposiums, this program will

New Appraisal Threshold Now Effective

Adam Witmer
Regulatory Update

As we reported last week, the regulators issued joint guidance to increase the threshold for residential real estate transactions requiring an appraisal from $250,000 to $400,000.  The appraisal threshold adjustment was effective the day after publication in the Federal Register.  Since the final rule was published on 10/8/19, the new $400,000 threshold is now in effect and can be utilized by banks on applicable loans.

For those looking for a comprehensive break-down of the new appraisal threshold rules, we will be offering training on this topic as both part of our 3Q 2019 Quarterly Compliance Update as well as a stand-alone product. Those programs will both be available in our store at www.compliancecohort.com/store over the next few weeks.

FinCEN Updates CTR FAQ 16 - Again...

Adam Witmer
BSA, Regulatory Update

Over the last week, FinCEN updated their CTR Frequently Asked Question (FAQ) # 16 - for the third time in recent days. A few weeks ago, FinCEN started the process of changing how they want CTR filers to complete CTRs when a person has multiple “roles” in the transaction. Initially, FinCEN updated CTR FAQ 16 with a new answer, but then reverted to the original answer to FAQ 16 after apparent multiple calls from bankers questioning this change (that did not have an associated announcement or even changes to the CTR instructions). This week, we have received reports that FinCEN released a statement

OCC Releases Supervision Operating Plan for 2020

Adam Witmer
Regulatory Update

On October 1, 2019, the Office of the Comptroller of the Currency (OCC) released its bank supervision operating plan for fiscal year 2020.  This annual plan outlines how the OCC plans to focus their supervision of individual national banks, federal savings associations, federal branches, federal agencies, and technology service providers.  In their announcement, the OCC explains that they plan to focus on the following areas for 2020:

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