FDIC Seeks Comments on Small Dollar Lending

Adam Witmer
Regulatory Update

The FDIC has requested public comments on issues related to small-dollar lending by FDIC-Supervised financial institutions.  Specifically, feedback is being requested regarding consumer demand for small-dollar credit products, the supply of small-dollar credit products currently offered by banks, and what the FDIC can do to facilitate increase small-dollar lending.

Conducting BSA Board Training

Conducting BSA Board Training

Adam Witmer
BSA

This Compliance Clip (video) provides a number of practical tips on how to execute a good BSA training session for your Board of Directors. Adam provides three main things that could be included in Board training and explains several best practices for ensuring an effective training session. The video concludes by discussing a valuable resource that may assist some BSA Officers in training their Board.

Enter to Win a Free Compliance Class!!!

Adam Witmer

The Holiday madness is right around the corner, so we thought it might be a good time to give back to one of our members. You see, we are in the process of developing a new Compliance Class called “BSA Bootcamp! Training for Those New to BSA,” and have decided to hold a drawing to give away this class to one of our members.

If you would like a chance to win this BSA Compliance Class, send an email to compliance@compliancecohort.com by the end of day on Monday, November 19, 2018. While the class won’t be available for a few weeks still, the drawing will be held on Tuesday, November 20, 2018.

Joint Statement on OFAC Cyber-Related Sanction Risks

Adam Witmer
BSA

On November 5, 2018, the FFIEC released a joint statement to alert financial institutions to recent actions taken by the Treasury’s Office of Foreign Assets Control (OFAC).  These actions were taken under OFAC’s Cyber-Related Sanctions Program and have potential impact on financial institution’s operations, including the use of services of a sanctioned entity.

Adverse Action Reasons Chart

Adam Witmer
Regulation B, Fair Lending

When a financial institution denies an application, Regulation B sets forth several requirements that must be met.  Among other things, financial institutions are required to notify an applicant of the denial and (as applicable) provide the applicant with a “statement of specific reasons” for denial.  One of the biggest challenges in providing the specific reasons for denial is determining which adverse action reasons should be listed on the denial notice. As Regulation B does not explain what reasons should be used, financial institutions benefit from creating an Adverse Action Reasons Chart. This article provides a sample adverse action chart that could be used by financial institutions.

CFPB Issues Statement on Payday Rule Reconsideration and Delayed Compliance Date

Adam Witmer
Regulatory Update

On October 26, 2018, the CFPB issued a statement regarding their planned payday rule.  Specifically, the CFPB explained that they expect to issue proposed rules in early 2019 that will reconsider the Payday, Vehicle Title, and Certain High-Cost Installment Loans rule.  They also plan to address the rule’s compliance date in this 2019 issuance. In their statement, the CFPB explained that they will make final decisions regarding the scope of the proposal closer to the issuance of the proposed rules. They also said, however, that

FDIC Proposes to Rescind Annual Disclosure Statement Requirements

Adam Witmer
Regulatory Update

On October 25, 2018, the Federal Deposit Insurance Corporation (FDIC) issued a proposed rule to rescind and remove its regulations relating to the disclosure of financial and other information by FDIC-insured state nonmember banks. Upon the removal of the regulations, applicable FDIC-regulated banks would no longer be subject to the annual disclosure statement requirement found in those regulations. The financial and other information that has been subject to disclosure by individual banks pursuant to these regulations is publicly available through the FDIC's website.

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