All in Regulatory Update

OCC Fines City National Bank $65 Million

Adam Witmer
Regulatory Update

On January 31, 2024, the OCC assessed a $65 million civil money penalty against City National Bank related to systemic deficiencies in the Bank’s risk management and internal controls. The agency also issued a cease-and-desist order requiring the bank to take broad and comprehensive corrective actions to improve its strategic plan, operational risk management, compliance risk management, strategic risk management, and investment management practices.

FinCEN Requests Comments for BOI Requests

Adam Witmer
BSA, Regulatory Update

On January 30, 2024, FinCEN issued a notice and request for comments on the proposed information collection associated with requests made to FinCEN, by certain persons, for beneficial ownership information, consistent with the requirements of the Beneficial Ownership Information Access and Safeguards final rule. The BOI Access Rule implements CTA's strict data protection rules for sensitive personal information sent to FinCEN.

FinCEN Proposes Rule and Identifies Al-Huda Bank as Primary Money Laundering Concern

Adam Witmer
BSA, Regulatory Update

On January 29, 2024, FinCEN issued a finding and notice of proposed rulemaking that identifies Al-Huda Bank, an Iraqi bank that serves as a conduit for terrorist financing, as a foreign financial institution of primary money laundering concern. Along with its finding, FinCEN proposed imposing a special measure that would sever the bank from the U.S. financial system by prohibiting domestic financial institutions and agencies from opening or maintaining a correspondent account for or on behalf of Al-Huda Bank.

FRB Fines Foreign Bank for Unauthorized Disclosure of Supervisory Information

Adam Witmer
Regulatory Update

On January 19, 2024, the Federal Reserve Board issued an enforcement action and fined the Industrial and Commercial Bank of China Ltd. and its New York branch approximately $2.4 million for their unauthorized use and disclosure of confidential supervisory information. It is illegal to disclose confidential supervisory information which includes reports of bank examinations and other confidential communications by banking regulators without prior approval of the appropriate banking regulator.

FDIC Updates Consumer Compliance Exam Manual

Adam Witmer
Regulatory Update

On January 12, 2024, the FDIC updated sections of the Consumer Compliance Examination Manual. The Consumer Compliance Examination Manual is a primary resource and reference tool for FDIC compliance examination staff when conducting Consumer Compliance and CRA examinations. It incorporates examination policies, procedures, and guidance and is available on the FDIC website as a resource for FDIC staff, bankers, and other members of the public.

CFPB Issues Guidance on Background Screening and File Disclosures in Credit Reporting

Adam Witmer
Regulatory Update

On January 11, 2024, the CFPB issued guidance to consumer reporting companies to address inaccurate background check reports, as well as sloppy credit file sharing practices. In particular, the Bureau issued two advisory opinions with the aim to ensure that the consumer reporting system produces accurate and reliable information and does not keep people from accessing their personal data. 

FDIC Updates its Risk Management Manual of Examination Policies

Adam Witmer
Regulatory Update

On January 5, 2024, the FDIC revised parts of its Risk Management Manual of Examination Policies. The FDIC conducts examinations to help ensure the stability of insured depository institutions by identifying undue risks and weak risk management practices. 

The FDIC revised section 3.1 Asset Quality to to separate FDIC-only explanatory instructions from the specific Uniform Financial Institutions Rating System (UFIRS) Asset Quality component rating language.

The updated RMS manual can be found here.

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