All in Regulatory Update

CFPB Issues Guidance for PSLF Communications

Adam Witmer
Regulatory Update

On 2/18/2022, the CFPB issued a Compliance Bulletin and Policy Guidance regarding the servicing of Federal student loans, including Federal Family Education Loan Program and Perkins loans, for borrowers who may be eligible for Public Service Loan Forgiveness (PSLF). The Limited PSLF Waiver announced by the Department of Education on October 6, 2021 significantly changes the program’s eligibility criteria for a limited period. Thus, servicers should consider taking certain actions to ensure compliance with the Dodd-Frank Act’s prohibition on unfair, deceptive, or abusive acts or practices.

Agencies to Release CRA Proposal

Adam Witmer
Regulatory Update, CRA

On 2/14/2022, Acting Comptroller of the Currency Michael J. Hsu spoke before the National Community Reinvestment Coalition where he announced that the OCC, the Federal Reserve, the FDIC will release a joint CRA Notice of Proposed Rulemaking (NPR) in the not-too-distant future. This step, according to Hsu, is aimed at strengthening and modernizing the regulation implementing the CRA in order to expand financial access and inclusion for low- and moderate-income (LMI) communities.

FinCEN Issues RRP Fact Sheet

Adam Witmer
Regulatory Update

On 2/14/2022, the FinCEN issued a fact sheet on its Rapid Response Program (RRP). RRP is a collaborative partnership that leverages FinCEN’s relationships with law enforcement, U.S. financial institutions, and foreign financial intelligence units to help victims and their financial institutions recover funds stolen as the result of certain cyber-enabled financial crimes schemes, including business e-mail compromise.

CFPB Sees Changes in Banks's Overdraft Programs

Adam Witmer
Regulatory Update

On 2/10/2022, the CFPB released a blog post discussing the changes that banks are making to their overdraft programs. The CFPB also prepared a table comparing overdraft fees and policies across banks. According to the CFPB, they will continue to monitor these developments to better understand the impact of these changes, and to work to ensure that banks continue to evolve their businesses to reduce reliance on overdraft and NSF fees.

Federal Reserve Issues Fraud Mitigation Toolkit

Adam Witmer
Regulatory Update, BSA

In early February, 2022, the Federal Reserve released a Synthetic Identity Fraud Mitigation Toolkit which offers a wide variety of informative resources for financial institutions, consumers and businesses on fraud mitigation. The issuance of the fraud mitigation toolkit is the next step in the Federal Reserve’s years-long commitment and engagement with fraud experts to support the payments industry in its battle against fraud.

FinCEN Releases Update on the BOI Reporting

Adam Witmer
Regulatory Update

On 2/8/2022, the FinCEN announced that the comment period to the notice of proposed rulemaking (NPRM) requiring the reporting of beneficial ownership information (BOI), tagged as Reporting NPRM, has closed. FinCEN received at least 230 comments. The next step in the CTA rulemaking series will be the publication of proposed rules on BOI access and disclosure requirements, which will be known as the “Access NPRM”, and which the FinCEN plans to publish later this year.

VIDEO: Are Changes Coming to Overdraft Programs?

VIDEO: Are Changes Coming to Overdraft Programs?

Adam Witmer
Regulatory Update, Regulation B

In this Compliance Clip (video), Adam shares some interesting hints of change that relate to overdraft protection programs. While nothing has been formally planned to be changed, this video shows several actions by the regulators which could be a foreshadow to changes with guidance for overdraft protection programs. If your organization has an overdraft protection program, you won’t want to miss this 7 minute video. A transcript of this video is now available.

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