In February of 2020, the CFPB released the Winter 2020 edition of their Supervisory Highlights publication. The findings included in this edition cover examinations in the areas of debt collection, mortgage servicing, payday lending, and student loan servicing that were completed between April 2019 and August 2019.

The full Winter 2020 edition of the CFPB’s Supervisory Highlights can be found here.

On February 18, 2020, the CFPB published a blog post titled “Five ways to recognize a Social Security scam.” The article begins by explaining that Social Security scams are the most commonly reported type of fraud and scam, and such scams are continuing to evolve. Therefore, it is important that consumer understand how to recognize a scam in order to protect themselves from illicit actors.

Expiration Date for Revised Loan Estimates

In this Compliance Clip (video), Adam explains what to do with the expiration date on a revised Loan Estimate after the intent to proceed is received by consumers and provides a background on why there has been confusion in the industry over this minor detail or TRID. If you or your team didn’t catch this change with TRID 2.0 (in 2018), you will want to be sure to catch this video.

The Federal Financial Institutions Examination Council (FFIEC) has issued the 2020 edition of A Guide to HMDA Reporting Getting It Right! for Home Mortgage Disclosure Act-related data collected in 2020 and reported in March of 2021. The 2020 edition reflects updates to incorporate content from the HMDA Rule issued by the Consumer Financial Protection Bureau in October 2019. This compliance resource can help financial institutions better understand HMDA requirements, including the data collection and reporting provisions.

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

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.)

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.

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…

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.