FinCEN to Update CTR Reporting

Adam Witmer
BSA, Regulatory Update

On February 10, 2020, the Financial Crimes Enforcement Network (FinCEN) issued a ruling relating to filing Currency Transaction Reports (CTRs) for sole proprietorships and legal entities operating under a “Doing Business As” (DBA) name. This short two-page ruling outlines how CTRs should be filed, starting on April 6, 2020 (and September 1, 2020 for batch filers). Unfortunately, this guidance is not clear and concise and actually seems to complicate things, so BSA Officers should take a close look at it. As you might expect, this topic will be included in our next Quarterly Compliance Update planned for April 2020.

10-Step Implementation Plan for Reg CC Changes

10-Step Implementation Plan for Reg CC Changes

Adam Witmer
Regulation CC

This video outlines a 10-step plan that can be used to implement the recent amendments to Regulation CC that have required compliance by July 1, 2020. While the Regulation CC amendments may appear to be minimal changes to the actual rules, the impact to financial institutions is going to be much more significant. In fact, there are plenty of things that need to be done by July 1, 2020 to ensure compliance, and this video will provide you and your team with a framework for doing just that. (And if you aren’t responsible for implementing the Reg CC changes, you might consider forwarding this on to your colleagues who are going to tackle these cumbersome changes.)

CFPB Fall 2019 Annual Report to Congress

Adam Witmer
Regulatory Update

On February 3, 2020, the CFPB released their semi-annual report for the Fall of 2019. This version of the regular report to Congress covers the period beginning on April 1, 2019 and ending on September 30, 2019. As is the case in each semi-annual report to Congress, the CFPB includes a number of topics ranging from challenges consumers face to a summary of new rules adopted by the Bureau.

MOU Between CFPB & Department of Education

Adam Witmer
Regulatory Update

On 2/3/2020, the Consumer Financial Protection Bureau (Bureau) and the U.S. Department of Education (ED) announced a renewed coordination agreement - through a Memorandum of Understanding (MOU) - in order to better serve student loan borrowers.  In doing this, the agencies will share complaint information from borrowers and regularly to discuss observations about the nature of complaints received, characteristics of borrowers, and available information about resolution of complaints. The MOU more clearly defines…

Summary of Reg CC Changes for July 2020

Adam Witmer
Regulation CC

In this article, we provide a summary of the Reg CC changes that financial institutions must comply with by July 1, 2020. In addition to the summary, this article provides a 10-step implementation plan for complying with the recent changes. Now is the time to get started implementing the new Reg CC rules, and it is our hope that this article can assist you in a successful implementation of the new rules.

CFPB Updates HMDA Guide

Adam Witmer
Regulatory Update, HMDA

On January 23 of 2020, the CFPB released their latest version (v.4) of their HMDA Small Entity Compliance Guide. The updates in this version of the guide were made to align the guide with the October 10, 2019 final rule which implements the partial exemption for small filers.

CFPB Fines Bank for Credit Card Dispute Process

Adam Witmer
Regulatory Update

On 1/30/2020, the CFPB filed suit against Citizens Bank, N.A. (Providence, Rhode Island) based on allegations that the bank violated the Truth in Lending Act (TILA) and its implementing Regulation Z, including violations of amendments to TILA contained in the Fair Credit Billing Act and the Credit Card Accountability Responsibility and Disclosure Act.

LAST CHANCE! Early Bird Sale Ending for Winter 2020 Quarterly Compliance Update

Adam Witmer

Today is the last day to get the “early bird” discount on our new Winter 2020 Quarterly Compliance Update. This program is jam-packed with all of the need-to-know regulatory compliance activity that took place during the fourth quarter of 2019. Topics include a ton of activity like TRID updates, URLA implementation, miscellaneous agency activity, the CRA proposal, HMDA changes, and more. This quarter, we even have an entire video dedicated to fair lending as we review some fair lending hot topics the regulators have been talking about. The full curriculum for this program can be viewed at: www.compliancecohort.com/winter-2020-quarterly-compliance-update.

OCC Hammers Former Wells Fargo Execs with Fines

Adam Witmer
Regulatory Update, Compliance Management

On January 23, 2020, the Office of the Comptroller of the Currency (OCC) issued a notice of charges against five former senior executives of Wells Fargo Bank, N.A., Sioux Falls, South Dakota, and announced settlements with the bank’s former Chief Executive Officer (CEO) and other members of the bank’s operating committee - including the former chief auditor, a former risk officer, former general counsel, and a former executive audit director.

This notice of charges is of particular interest to compliance and audit professionals as risk managers, auditors, and general counsel don’t typically appear in these types of charges.

The notice of charges alleges these executives…

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