On March 31, 2020, the Financial Action Task Force (FATF) released a report regarding the measures taken by the United States to strengthen their money laundering framework. In their report, FATF found that the United States has been in an enhanced follow-up process following the adoption of its mutual evaluation in 2016, after the 2016 FATF evaluation. In line with the FATF Procedures for mutual evaluations, the country has reported back to the FATF on the actions it has taken since then.

On April 1, 2020, the CFPB announced a settlement with Cottonwood Financial, Ltd., which does business under the name Cash Store, operating in several states and based in Texas. The CFPB found that in the course of marketing, servicing, and collecting on high-interest payday, auto-title, and unsecured consumer-installment loans Cash Store violated several consumer protection laws including the Consumer Financial Protection Act (CFPA), Fair Credit Reporting Act (FCRA), and Truth in Lending Act (TILA). The consent order includes $1.3 million in monetary restitutions and fines.

On March 31, 2020, the CFPB released a guide to assist consumers with understanding their mortgage relief options. The guide is designed by those financially impacted by the coronavirus pandemic and who might be concerned about how to pay their mortgage or rent. Federal and state governments have announced plans to help struggling homeowners during this time and the CFPB guide provides information on what consumers can do now, and what their options are for mortgage and rental relief.

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.

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

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.

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).