All in Regulatory Update

FinCEN Reveals Increase in SARs Related to Wildlife Trafficking

Adam Witmer
BSA, Regulatory Update

On 12/20/21, FinCEN released a Financial Threat Analysis on wildlife trafficking threat patterns and trend information identified in Bank Secrecy Act (BSA) data filed between January 2018 and October 2021. The result of the analysis shows that wildlife trafficking-related SARs filed between January 2018 and October 2021 trended significantly up and SARs filed in 2021 are on track to meet or exceed the amount of SARs filed in 2020 based on current trends.

OCC Updates Comptroller's OREO Handbook

Adam Witmer
Regulatory Update

On 12/20/21, the OCC issued an updated "Other Real Estate Owned" booklet of the Comptroller’s Handbook, which is prepared for use by OCC examiners in connection with the examination and supervision of national banks, federal savings associations, and federal branches and agencies of foreign banking organizations (collectively, banks).

CommunityBank of Texas Charged $8 Million for BSA Violations

Adam Witmer
Regulatory Update, BSA

On 12/16/21, FinCEN and the OCC announced on separate issuances that they assessed a total of $8 million civil money penalty on CommunityBank of Texas, N.A. (CBOT) for willful violations of the Bank Secrecy Act (BSA) and its implementing regulations. As a result of its own investigation, the OCC assessed a civil penalty of $1 million for related violations while FinCEN agreed with CBOT to a settlement of $7 million.

Agencies Release CRA Asset-Size Thresholds for 2022

Adam Witmer
CRA, Regulatory Update

On 12/16/21, the Federal Reserve Board and the FDIC issued the 2022 updated asset-size thresholds used to define "small bank" and "intermediate small bank" under their Community Reinvestment Act (CRA) regulations. Small bank means an institution that, as of December 31 of either of the prior two calendar years, had assets of less than $1.384 billion. Intermediate small bank means a small institution with assets of at least $346 million as of December 31 of both of the prior two calendar years and less than $1.384 billion as of December 31 of either of the prior two calendar years.

FinCEN Seeks Comments on Modernization AML/CFT Regulatory Regime

Adam Witmer
Regulatory Update, BSA

On 12/14/21, FinCEN issued a request for information (RFI) seeking comments on ways to streamline, modernize, and update the anti-money laundering and countering the financing of terrorism (AML/CFT) regime of the United States. The agency is particularly interested in ways to modernize risk-based AML/CFT regulations and guidance so that they can continue to protect U.S. national security in a cost-effective and efficient manner.

OCC Issues Final Rule to Rescind its 2020 CRA Rule

Adam Witmer
Regulatory Update, CRA

On 12/14/21, the OCC issued a final rule on Community Reinvestment Act (CRA) to rescind the June 2020 rule. In their release, the OCC explained that this is to facilitate the ongoing interagency work to modernize the CRA regulatory framework and promote consistency for all insured depository institutions. The June 2020 rule will be replaced with a rule based on the rules adopted jointly by the Federal banking agencies in 1995, as amended. The OCC explained that these actions are intended to facilitate the ongoing interagency work to modernize the CRA regulatory framework and promote consistency for all insured depository institutions.

CFPB Supervision Activities Uncover Red Flags

Adam Witmer
Regulatory Update

On 12/9/2021, the CFPB published a blog post titled “Seven examples of unfair practices and other violations by mortgage servicers: CFPB supervision activities uncover red flags.” In their post, the CFPB explains that during the pandemic, families struggle to afford their mortgage payments. It was noted that over 7 million homeowners entered forbearance programs to defer their monthly payments.

Load More