All in Regulatory Update

On March 10, 2022, FinCEN issued a press release to inform U.S. financial institutions that the Financial Action Task Force (FATF), an intergovernmental body that establishes international standards to combat money laundering, counter the financing of terrorism, and combat weapons of mass destruction proliferation financing (AML/CFT/CPF), has issued public statements updating its lists of jurisdictions with strategic AML/CFT/CPF deficiencies following its plenary meeting this month. U.S. financial institutions should consider the FATF’s stance toward these jurisdictions when reviewing their obligations and risk-based policies, procedures, and practices.

On March 7, 2022, Acting Comptroller of the Currency Michael J. Hsu spoke at the at the Institute of International Bankers Annual Washington Conference where he discussed climate-related financial risk and the importance of promoting diversity and inclusion in the banking industry. The IIB, according to Hsu, has a long history of bringing together senior government officials and industry leaders to address policy and business issues of importance to the international banking community in the United States.

On March 3, 2022, the U.S. Department of the Treasury convened a virtual discussion, “The Climate Transition: Federal Policy and State and Local Government Best Practices.” The participants discussed the steps that state and local governments are taking to include climate data into municipal capital planning processes, develop innovative tools and policies to finance climate mitigation and transition projects, and disclose climate-related financial risks to municipal market participants.

On March 1, 2022 the CFPB issued a report highlighting the complicated and burdensome nature of the medical billing system in the United States. The report reveals that the U.S. healthcare system is supported by a billing, payments, collections, and credit reporting infrastructure where mistakes are common, and where patients often have difficulty getting these errors corrected or resolved.

On February 28, 2022, the CFPB issued a compliance bulletin regarding repossession of vehicles, and the potential for violations of the Dodd-Frank Act’s prohibition on engaging in unfair, deceptive, or abusive acts or practices when repossessing vehicles. This is after the CFPB observed, during its examinations and enforcement actions, illegal seizure of cars, sloppy record keeping, unreliable balance statements, and ransom for personal property.