All in Regulatory Update

FinCEN to Update CTR Reporting

Adam Witmer
BSA, Regulatory Update

On February 10, 2020, the Financial Crimes Enforcement Network (FinCEN) issued a ruling relating to filing Currency Transaction Reports (CTRs) for sole proprietorships and legal entities operating under a “Doing Business As” (DBA) name. This short two-page ruling outlines how CTRs should be filed, starting on April 6, 2020 (and September 1, 2020 for batch filers). Unfortunately, this guidance is not clear and concise and actually seems to complicate things, so BSA Officers should take a close look at it. As you might expect, this topic will be included in our next Quarterly Compliance Update planned for April 2020.

CFPB Fall 2019 Annual Report to Congress

Adam Witmer
Regulatory Update

On February 3, 2020, the CFPB released their semi-annual report for the Fall of 2019. This version of the regular report to Congress covers the period beginning on April 1, 2019 and ending on September 30, 2019. As is the case in each semi-annual report to Congress, the CFPB includes a number of topics ranging from challenges consumers face to a summary of new rules adopted by the Bureau.

MOU Between CFPB & Department of Education

Adam Witmer
Regulatory Update

On 2/3/2020, the Consumer Financial Protection Bureau (Bureau) and the U.S. Department of Education (ED) announced a renewed coordination agreement - through a Memorandum of Understanding (MOU) - in order to better serve student loan borrowers.  In doing this, the agencies will share complaint information from borrowers and regularly to discuss observations about the nature of complaints received, characteristics of borrowers, and available information about resolution of complaints. The MOU more clearly defines…

CFPB Updates HMDA Guide

Adam Witmer
Regulatory Update, HMDA

On January 23 of 2020, the CFPB released their latest version (v.4) of their HMDA Small Entity Compliance Guide. The updates in this version of the guide were made to align the guide with the October 10, 2019 final rule which implements the partial exemption for small filers.

CFPB Fines Bank for Credit Card Dispute Process

Adam Witmer
Regulatory Update

On 1/30/2020, the CFPB filed suit against Citizens Bank, N.A. (Providence, Rhode Island) based on allegations that the bank violated the Truth in Lending Act (TILA) and its implementing Regulation Z, including violations of amendments to TILA contained in the Fair Credit Billing Act and the Credit Card Accountability Responsibility and Disclosure Act.

OCC Hammers Former Wells Fargo Execs with Fines

Adam Witmer
Regulatory Update, Compliance Management

On January 23, 2020, the Office of the Comptroller of the Currency (OCC) issued a notice of charges against five former senior executives of Wells Fargo Bank, N.A., Sioux Falls, South Dakota, and announced settlements with the bank’s former Chief Executive Officer (CEO) and other members of the bank’s operating committee - including the former chief auditor, a former risk officer, former general counsel, and a former executive audit director.

This notice of charges is of particular interest to compliance and audit professionals as risk managers, auditors, and general counsel don’t typically appear in these types of charges.

The notice of charges alleges these executives…

Overview of CRA Proposal

Overview of CRA Proposal

Adam Witmer
CRA, Regulatory Update

In this Compliance Clip (video), Adam briefly discusses the recent CRA proposal by providing an overview of the goals of the proposal. Adam also discusses how, if passed as proposed, this new rule would have some major changes to Assessment Areas that may have negative effects on banks. Comments are due soon on this proposal, so watch this video to learn how the changes might affect your bank.

NCUA Releases Priorities for 2020

Adam Witmer
Regulatory Update

On January 7, 2020, the NCUA announced that it had issued its annual letter to credit unions listing its 2020 supervisory priorities as well as updates on regulations and the agency’s modernization programs.

The letter includes a summary of recent statutory and regulatory updates, including additional guidance on serving legal hemp businesses; changes in the appraisal threshold for commercial real estate transactions; the amended supervisory committee audits rule, which took effect Jan. 6; and the amended public unit and nonmember shares rule, which takes effect Jan. 29. For 2020, the NCUA has listed the following as supervisory priorities:

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