Jun 7
Jun 7 Reg CC Training for Tellers Available

As July 1, 2020 is quickly approaching, there are a number of steps that must be taken to ensure compliance with the new Reg CC rules that will become effective at that time. If your institution is still trying to figure out how to train your team on the new Reg CC changes by July 1, 2020, our Reg CC Training for Tellers program may be a fit for you as it is designed to walk you through the changes while also delivering training to your team in a remote (electronic delivery) format. You can learn more about this program (and view sample clips of the actual program) at https://www.compliancecohort.com/reg-cc-training-for-tellers.

Jun 5

Jun 5 VIDEO: Reg B Data Collection for Ag or Commercial Loans

Adam Witmer

Regulation B

In this Compliance Clip (video), Adam answers a question for a member about Reg B data collection of government monitoring information (GMI) for agricultural loans. This abnormally long Compliance Clip lasts over 10 minutes and goes over three different scenarios. This clip would be great for any newly exempt HMDA reporter who will soon be transitioning to GMI collection under Reg B instead of DI information under HMDA.

Jun 4
Jun 4 CFPB Statement on ESIGN for Credit Cards

Adam Witmer

Regulatory Update

On 6/3/2020, the CFPB issued a statement on supervisory and enforcement practices regarding electronic credit card disclosures in light of the COVID-19 pandemic. The Bureau explained in their release that they issued this statement to provide temporary and targeted flexibility for credit card issuers regarding electronic provision of certain disclosures required to be in writing during this pandemic. The Bureau also explained that this supervisory and enforcement flexibility will facilitate credit card issuers’ ability to quickly assist consumers during the pandemic.

Jun 3
Jun 3 CFPB Settles on UDAAP Case

Adam Witmer

Regulatory Update

On 6/2/2020, the CFPB announced a settlement with Main Street Personal Finance, Inc. and its subsidiaries which are based in Cleveland, Tennessee and offer payday and auto-title loans. The Bureau found that Approved Cash provided deceptive finance charge disclosures by failing to refund overpayments on its loans, and violated laws by engaging in unfair debt collection practices.

Specifically, the Bureau found that Approved Cash violated the CFPA’s prohibition against engaging in deceptive acts or practices and TILA by concealing and understating the actual finance charges of its auto-title loans for over 4,000 consumers, who paid a total of over $3.5 million more than the finance charge listed in Approved Cash’s loan disclosures. The Bureau also found…

Jun 2
Jun 2 CFPB Provides Remittance Transfer FAQs

Adam Witmer

Regulatory Update

On 6/2/2020, the CFPB issued Compliance Aid to assist financial institutions with understanding their responsibilities for the remittance transfer rule in light of the COVID-19 pandemic. This three page document provides three questions and answers for applicable financial institutions.

Jun 2
Jun 2 NCUA Delays Resumption of Onsite Operations

Adam Witmer

Regulatory Update

In late June of 2020, the NCUA announced that it was delaying the start of it phased resumption of onsite operations. According the the NCUA, the delay was warranted based on factors like recent trends in public health data and administrative considerations. The agency explained that they will continue offsite examinations as they have done for the last several months.

Jun 2
Jun 2 CFPB Info on Government Imposter Scams

Adam Witmer

Regulatory Update

On 6/1/2020, the CFPB issued guidance for consumers on how they can avoid COVID-19 government imposter scams. Tips provided by the CFPB include three ways consumers can protect themselves and others from scammers:

May 27
May 27 OCC Interim Final Rule on Remote Board Attendance

Adam Witmer

Regulatory Update, Compliance Management

On 5/26/2020, the OCC issued Bulletin 2020-55 to clarify that national banks and federal savings associations may permit telephonic and electronic participation at all board of directors, shareholder, and, as applicable, member meetings.

May 27
May 27 FinCEN Requests Comments on SAR Burden

Adam Witmer

BSA, Regulatory Update

On 5/26/2020, FinCEN published a notice and request for comment in the Federal Register. While no substantial changes to SAR reporting are included in the issuance, FinCEN is requesting comments regarding FinCENs updated burden estimate for SARs. Comments must be received on or before July 27, 2020.

May 26
May 26 SBA Issues two PPP Rules

Adam Witmer

Regulatory Update

On 5/22/2020, the Small Business Administration (SBA) issued two interim final rules implementing the Paycheck Protection Program (PPP). The first interim final rule provides requirements for loan forgiveness while the second explains the SBA loan review procedures and related borrower and lender responsibilities.