FFIEC COVID-19 Guidance

Adam Witmer
Regulatory Update, Business Continuity

On March 25, 2020 the Federal Financial Institutions Examination Council (FFIEC) released a statement that the regulatory agencies are continuing to monitor and respond to the COVID-19 pandemic to promote the ongoing ability of the nation’s financial institutions to support the households and businesses that depend on them. This article highlights the FFIEC guidance.

FFIEC Statement on Pandemic Preparedness Guidance

Adam Witmer
Regulatory Update, Compliance Management

On March 6, 2020, the Federal Financial Institutions Examination Council updated guidance identifying actions that financial institutions should take to minimize the potential adverse effects of a pandemic. The guidance provides the FFIEC’s expectations that regulated institutions should periodically review related risk management plans, including continuity plans, to ensure their ability to continue to deliver their products and services in a wide range of scenarios and with minimal disruption.

FinCEN Guidance for COVID-19 SARs

FinCEN Guidance for COVID-19 SARs

Adam Witmer
BSA

In this Compliance Clip (free video), Adam explains the recent FinCEN guidance regarding COVID-19 and BSA/AML requirements. Specifically, there are four main parts to this guidance and Adam breaks each down in easy-to-understand language. Plus, your BSA Officer won’t want to miss the final part of the guidance which has a direct requirement for filing SARs relating to COVID-19.

FinCEN Encourages Communication on COVID-19 & Warns of Fraud

Adam Witmer
BSA, Regulatory Update

On March 16, 2020, FinCEN issued a request that financial institutions affected by the COVID-19 pandemic contact FinCEN and their functional regulator as soon as practicable if a COVID-19-affected financial institution has concern about any potential delays in its ability to file required Bank Secrecy Act (BSA) reports. FinCEN also states that institutions seeking to contact them should call FinCEN’s Regulatory Support Section (RSS).

CFPB Issues New HMDA FAQ

Adam Witmer
Regulatory Update, HMDA

On March 6, 2020, the CFPB issued a new HMDA FAQ to clarify how to report when a natural person applicant submits a mail, internet, or telephone application under Regulation C, but does not provide race, ethnicity, or sex information. Specifically, question 7 under the “Ethnicity, Race, and Sex” section of the FAQs has been updated to provide additional guidance.

Negative Information Notice

Negative Information Notice

Adam Witmer
FCRA

In this Compliance Clip (video), Adam explains the regulatory requirements for the negative information notice. While the Fair Credit Reporting Act is one of the most dreadful and boring regulations found in the entire complianceverse, Adam does his best in this video to provide a bit of excitement to an otherwise soul sucking topic.

FDIC Extends Comment Period on Signage & Advertising Requirements

Adam Witmer
Regulatory Update

On 3/11/20, the FDIC extended the public comment period for its Request for Information (RFI) on potential ways to modernize the FDIC's sign and advertising rules. The rules, which were last updated in 2006 are being re-evaluated to better reflect how banks and savings associations are transforming their business models to take deposits via physical branches, digital, and mobile banking channels. Those wishing to comment may now submit comments through April 20, 2020. 

FATF Guidance on Digital ID

Adam Witmer
BSA, Regulatory Update

On March 6, 2020, the Financial Action Task Force (FATF) released guidance relating to digital ID systems. In their release, the FATF explains that an understanding of how digital ID systems work is essential to apply the risk-based approach recommended in this Guidance. Specifically, FATF said the following

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