All in Regulatory Update

CFPB Report on Complaints by Location

Adam Witmer
Regulatory Update, Compliance Management

On 9/23/21, the Consumer Financial Protection Bureau (CFPB) released its first in-depth report analyzing complaint submission patterns by U.S. Census tract. The report, “Consumer complaints throughout the credit life cycle, by demographic characteristics,” finds that the complaints from wealthier communities and communities with higher percentages of white, non-Hispanic residents were more frequently about loan origination and performing servicing, while the complaints from communities of color and lower income communities were more frequently about credit reporting, identity theft, and delinquent servicing.

SAR Guidance on Child Exploitation

Adam Witmer
BSA, Regulatory Update

On 9/16/21, the Financial Crimes Enforcement Network (FinCEN) issued a notice (FIN-2021-NTC3) to call attention to an increase in online child sexual exploitation (OCSE). The Notice provides financial institutions with specific suspicious activity report (SAR) filing instructions, and highlights some financial trends related to OCSE.

OCC Proposal to Rescind 2020 CRA Rule

Adam Witmer
Regulatory Update

On 9/8/2021, the OCC announced that it is soliciting comments on proposed rules to rescind the Community Reinvestment Act (CRA) rule issued in 2020 and replace it with rules adopted jointly by the Federal banking agencies in 1995, as amended. The OCC explains that the proposed rules would align the OCC’s CRA rules with the current Board of Governors of the Federal Reserve System and Federal Deposit Insurance Corporation rules and thereby facilitate the on-going interagency work to modernize the CRA regulatory framework and create consistency for all insured depository institutions.

CFPB Proposes Small Business Data Collection Rule

Adam Witmer
Regulatory Update, Regulation B

It’s finally here. After a decade of anticipation of the Dodd-Frank Act’s requirement for the CFPB to establish small business data reporting, the CFPB has issued a proposal on how they plan to implement the requirement of the Dodd-Frank Act.

As you would expect, this topic will be covered in our Fall 2021 Quarterly Compliance Update, which should be available in mid-to-late October, 2021.

OCC & DOJ Announce Redlining Settlement

Adam Witmer
Regulatory Update, Fair Lending

On 8/30/2021, the OCC and Department of Justice (DOJ) jointly announced an agreement to resolve allegations that Cadence Bank, which is headquartered in Atlanta, engaged in lending discrimination by “redlining” predominantly Black and Hispanic neighborhoods in the Houston, metro area. Under the department’s settlement, Cadence will invest over $5.5 million to increase credit opportunities for residents of those neighborhoods. In conjunction with this announcement, the OCC also announced that it has assessed penalties against the bank in the amount of $3 million related to the violations alleged in the department’s complaint.

Agencies Issue Guide on Fintech Relationships

Adam Witmer
Regulatory Update

On 8/27/2021, the Federal Reserve, FDIC, and OCC jointly issued a guide to help community banks assess risks when considering relationships with financial technology (fintech) companies. In the release, the agencies explained that community banks are entering into business arrangements with fintech companies to offer enhanced products and services to their customers, increase efficiency, and reduce internal costs. The agencies’ guide is intended to serve as a resource for community banks when performing due diligence on prospective relationships with fintech companies.

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