All in Regulatory Update

On March 30, 2023, the Federal Reserve Board announced that it has fined Wells Fargo & Company $67.8 million for the firm's unsafe or unsound practices relating to historical inadequate oversight of sanctions compliance risks at its subsidiary bank, Wells Fargo Bank, N.A. Wells Fargo & Co.'s deficient oversight enabled the bank to violate U.S. sanctions regulations by providing a trade finance platform to a foreign bank that used the platform to process prohibited transactions.

On March 24, 2023, FinCEN published its first set of guidance materials to aid the public, and in particular the small business community, in understanding upcoming beneficial ownership information (BOI) reporting requirements taking effect on January 1, 2024. The new regulations require many corporations, limited liability companies, and other entities created in or registered to do business in the United States to report information about their beneficial owners to FinCEN.

On March 20, 2023, the  CFPB issued a rule to make non-substantive corrections and updates to Bureau and other Federal agency contact information found at certain locations in Regulations B, E, F, J, V, X, Z, and DD, including Federal agency contact information that must be provided with Equal Credit Opportunity Act adverse action notices and the Fair Credit Reporting Act Summary of Consumer Rights. This final rule also revises the chapter heading, makes various non-substantive changes to Regulations B and V, and provides a Bureau website address where the public may access certain APR tables referenced in Regulation Z.

On March 15, 2023, the CFPB published the 2023 HMDA Institutional Coverage Chart  and 2023 HMDA Transactional Coverage Chart. The updated charts are effective January 1, 2023. The updated coverage charts reflect the reduced 25 closed-end loans in each of the previous two calendar years threshold for reporting closed-end applications and loans.

On March 10, 2023, the FATF issued the updated Guidance on Beneficial Ownership of Legal Persons will help countries implement the revised requirements of Recommendation 24. In March 2022, the FATF adopted amendments to Recommendation 24, or the Beneficial Ownership of Legal Persons, and its Interpretive Note which require countries to prevent the misuse of legal persons for money laundering or terrorist financing and to ensure that there is adequate, accurate and up-to-date information on the beneficial ownership and control of legal persons.