On April 9, 2025, FinCEN issued a Financial Trend Analysis focused on patterns and trends identified in BSA data linked to fentanyl-related illicit finance. The BSA data filed between January and December 2024 included 1,246 reports identifying suspected fentanyl-related activity including precursor chemical procurement, fentanyl trafficking, and fentanyl-linked money laundering.

Apr 9
Apr 9 OCC Updates Contact Information for Certain CRA, FHA, ECOA Notices and Posters

Adam Witmer

CRA, Fair Lending, Regulatory Update

On April 8, 2025, the OCC issued a Bulletin to inform banks of the appropriate names and addresses for notices required by the CRA and ECOA and for posters required by the FHA. Banks must implement the necessary changes within 90 days of the bulletin's issuance date.

Apr 8
Apr 8 CFPB to Initiate New Rulemaking Process for Section 1071

Adam Witmer

Regulatory Update

On April 3, 2025, the ABA Banking Journal reported that the CFPB said in a court filing that its leadership has directed staff to initiate new rulemaking to implement Section 1071 of the Dodd-Frank Act and plans to soon release a proposal to possibly replace or change its current rule. The CFPB filed to the District Court for the Southern District of Florida an unopposed motion to stay the section 1071 rule and hold proceedings in abeyance.

Apr 7
Apr 7 FinCEN Issues Advisory on the Financing of ISIS

Adam Witmer

BSA, Regulatory Update

On April 1, 2025, FinCEN issued an Advisory to assist financial institutions in identifying and reporting suspicious activity related to the financing of the Islamic State of Iraq and Syria (ISIS). The Advisory outlines how ISIS funds itself through international support and various money transfer methods and also provides red flags for financial institutions to identify suspicious activity.

Apr 7
Apr 7 FDIC Updates Risk Manual of Exam Policies

Adam Witmer

Regulatory Update

On March 27, 2025, the FDIC released an update to its Risk Management Manual of Examination Policies. In particular, the section “Other Assets and Liabilities” was updated.

Apr 3
Apr 3 OCC Withdraws Climate Risk Principles for Large Financial Institutions

Adam Witmer

Regulatory Update

On March 31, 2025, the OCC withdrew its participation in the interagency principles for climate-related financial risk management for large financial institutions. In a statement, Acting Comptroller of the Currency Rodney E. Hood said “the principles providing guidance to banks for climate-related financial risk are overly burdensome and duplicative.”

Apr 1
Apr 1 CFPB Announces Availability of 2024 Mortgage Lending HMDA Data

Adam Witmer

HMDA, Regulatory Update

On March 28, 2025, the CFPB announced that the HMDA Modified Loan Application Register (LAR) data for 2024 are now available on the FFIEC’s HMDA Platform for approximately 4,898 HMDA filers. The published data contain loan-level information filed by financial institutions and modified to protect consumer privacy.

Apr 1
Apr 1 FinCEN Issues Alert on Bulk Cash Smuggling by Mexico TCOs

Adam Witmer

BSA, Regulatory Update

On March 31, 2025, FinCEN issued an Alert on bulk cash smuggling and repatriation by Mexico-based Transnational Criminal Organizations (TCOs). The Treasury, alongside FinCEN, is urging financial institutions to be vigilant in identifying and reporting transactions potentially related to the cross-border smuggling of bulk cash from the United States into Mexico and the repatriation of bulk cash into the U.S. and Mexican financial systems by these Mexico-based criminal organizations.

Apr 1
Apr 1 FDIC Issues Guidance on Banks’ Crypto-Related Activities

Adam Witmer

Regulatory Update

On March 28, 2025, the FDIC rescinded FIL-16-2022 and provided new guidance for FDIC-supervised institutions engaging or seeking to engage in crypto-related activities. FIL-16-2022, titled Notification of Engaging in Crypto-Related Activities, established a prior notification requirement for FDIC-supervised institutions that wish to engage in crypto-related activities.

Mar 31
Mar 31 Senate Votes to Overturn CFPB’s Overdraft Lending Final Rule

Adam Witmer

Regulatory Update

On March 28, 2025, the ABA Banking Journal reported that Senate has voted in favor of a resolution to overturn the CFPB’s limit on overdraft fees. On December 12, 2024, the CFPB amended Regulations E and Z to update rules for overdraft credit offered by very large banks.

Apr 10
Apr 10 FinCEN’s Analysis of Fentanyl-Related Threat Patterns and Trends in BSA Reports

Apr 9
Apr 9 OCC Updates Contact Information for Certain CRA, FHA, ECOA Notices and Posters

Apr 8
Apr 8 CFPB to Initiate New Rulemaking Process for Section 1071

Apr 7
Apr 7 FinCEN Issues Advisory on the Financing of ISIS

Apr 7
Apr 7 FDIC Updates Risk Manual of Exam Policies

Apr 3
Apr 3 OCC Withdraws Climate Risk Principles for Large Financial Institutions

Apr 1
Apr 1 CFPB Announces Availability of 2024 Mortgage Lending HMDA Data

Apr 1
Apr 1 FinCEN Issues Alert on Bulk Cash Smuggling by Mexico TCOs

Apr 1
Apr 1 FDIC Issues Guidance on Banks’ Crypto-Related Activities

Mar 31
Mar 31 Senate Votes to Overturn CFPB’s Overdraft Lending Final Rule

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