Welcome to the Compliance Cohort. We are a group of compliance professionals working to make compliance easier. Our goal is to take complex compliance concepts and put them in simple terms that apply to the real world. We are glad you have found us and look forward to collaborating in the future.
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On 4/16/20, the Small Business Administration (SBA) updated its website to reflect the fact that all available funds for the PPP program have been used up. Specifically, the SBA placed the following notice on its website:
“Lapse in Appropriations Notice: SBA is unable to accept new applications at this time for the Paycheck Protection Program or the Economic Injury Disaster Loan (EIDL)-COVID-19 related assistance program (including EIDL Advances) based on available appropriations funding.
On April 15, 2020, the FFIEC released a 43 page update to their BSA/AML Exam Manual. This long-awaited update includes many revisions designed to emphasize and enhance the regulators’ risk-focused approach to BSA/AML supervision. Click this link to see a summary of the major changes to the BSA/AML Exam Manual.
On 4/14/20, the banking regulators (except the NCUA) issued an interim final rule to temporarily defer real estate-related appraisals and evaluations under the agencies' interagency appraisal regulations. The Federal Reserve, FDIC, and OCC are providing this temporary relief to allow regulated institutions to extend financing to creditworthy households and businesses quickly in the wake of the national emergency declared in connection with COVID-19. The agencies are deferring certain appraisals and evaluations for up to 120 days after closing of residential or commercial real estate loan transactions. Transactions involving acquisition, development, and construction of real estate are excluded from this interim rule. These temporary provisions will expire on December 31, 2020, unless extended by the regulators.
On April 10, 2020, the CFPB issued a policy statement to ensure that consumers will be able to continue to send remittance transfers without disruption during the COVID-19 pandemic. More information can be found by clicking this link.
On 4/9/20, the Office of Foreign Assets Control published their annual inflation adjustments in the Federal Register. The rule, which is effective on April 9, 2020, is an annual requirements of OFAC and changes the amounts of 5 main civil money penalties.
FinCEN has released a FAQ regarding PPP loans which aligns with the FAQ issued by the SBA.
Our Spring 2020 Quarterly Compliance Update will be available in late April and will cover all consumer compliance activity that took place during the months of January, February, and March of 2020. Watch for more details about the availability of this program in the coming weeks.
The current discount for our Reg CC Training for Tellers program will be ending next week on Tuesday, April 14, 2020. This comprehensive training program is a solution that might make your life much easier over the next few months as you work to roll out the new changes to Regulation CC. Even if you are just barely considering getting outside assistance for training your team on the new Reg CC changes, it might be worth a few minutes to take a look at all of the great resources (and there are a bunch) that come with this program. And if you are considering this training, take a look before next Tuesday (4/14) as the price goes up after that day. Click here to learn more (and watch sample videos from the program): www.compliancecohort.com/reg-cc-training-for-tellers.
This Compliance Clip (video) explains when beneficial ownership information is needed for loan renewals. As Adam explains in this video, it is needed in some cases, but isn’t needed in other cases. Adam provides plenty of citations for views on this BSA topic.
On April 7, 2020, the CFPB issued a revised interagency statement encouraging financial institutions to work constructively with borrowers affected by COVID-19 and providing additional information regarding loan modifications. The revised statement also provides the agencies’ views on consumer protection considerations.
