All in Regulatory Update

CFPB Distributes Relief to Student Loan Debt-Relief Scam Victims

Adam Witmer
Regulatory Update

On November 13, 2023, the CFPB announced that 845 former Student Aid Institute (SAI) consumers will receive checks in the mail in response to a lawsuit filed against Frank Ronald Gebase Jr., the founder, owner, and operator of Processingstudentloans, a student loan debt-relief company that illegally withdrew hundreds of thousands of dollars from the bank accounts of former SAI consumers without their authorization. The total distribution amount is $240,994.00, and the money will come from the CFPB’s victims relief fund.

OCC Opens Registration for Symposium on Real-World Asset and Liability Tokenization

Adam Witmer
Regulatory Update

On November 13, 2023, the OCC announced that registration is open for its symposium on the tokenization of real-world assets and liabilities on February 8, 2024, at its headquarters in Washington, D.C. The symposium will include panel discussions among thought leaders, academics, community groups, and the banking industry on tokenization and is open to the public for in-person or virtual attendance.

CFPB Fines Citi $25.9 Million for Discrimination Against Armenian Americans

Adam Witmer
Regulatory Update, Fair Lending

On November 8, 2023, the CFPB ordered Citi to pay $25.9 million in fines and consumer redress for intentionally and illegally discriminating against credit card applicants the bank identified as Armenian American. According to CFPB Director Rohit Chopra, Citi purposefully discriminated against applicants of Armenian descent, primarily based on the spelling of their last name, and stereotyped Armenians as prone to crime and fraud. Chopra also said that Citi illegally fabricated documents to cover up its discrimination.

FinCEN and BIS Issue New SAR Key Term

Adam Witmer
BSA, Regulatory Update

On November 6, 2023, FinCEN and the BIS issued a new SAR key term to support financial institutions in reporting potential efforts to evade U.S. export controls beyond the Russia-related circumstances that were the focus of those prior two alerts. The new joint notice builds on the success of the two prior alerts issued jointly by the two agencies in generating suspicious activity reporting related to Russia-related export control evasion.

FinCEN Issues Updated FATF Deficient Countries

Adam Witmer
Regulatory Update, BSA

On November 3, 2023, 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 last 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.

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