Mar 11

Mar 11 VIDEO: What is Comparative Evidence of Disparate Treatment

In this Compliance Clip (video), Adam provides an overview of one of the three types of discrimination: comparative evidence of disparate treatment. This is the third and final video in our series on the three types of discrimination.

Mar 11
Mar 11 FinCEN Guidance on Art Trade

Adam Witmer

BSA, Regulatory Update

On 3/9/21, the Financial Crimes Enforcement Network (FinCEN) issued a notice (FIN-2021-NTC2) to inform financial institutions about (1) the Anti-Money Laundering Act of 2020 (the AML Act)1 efforts related to trade in antiquities and art, (2) select sources of information about existing illicit activity related to antiquities and art, and (3) provide specific instructions for filing Suspicious Activity Reports (SARs) related to trade in antiquities and art. This release encourages financial institutions to continue filing SARs regarding these topics and provides additional guidance.

Mar 10
Mar 10 CFPB Interpretive Rule on Sexual Orientation Discrimination

Adam Witmer

Regulation B, Regulatory Update

On March 9, 2021, the CFPB issued an interpretive rule clarifying that the prohibition against sex discrimination under the Equal Credit Opportunity Act (ECOA) and Regulation B includes sexual orientation discrimination and gender identity discrimination.

Mar 9
Mar 9 FATF Guidance on Risk-Based Supervision

Adam Witmer

BSA, Regulatory Update

On 3/4/21, the Financial Action Task Force (FATF) released guidance titled “Guidance on Risk-Based Supervision” to help financial industry supervisors address the full spectrum of risks and focus resources where the risks are highest. In their release, FATF explains that a risk-based approach will make supervisors efforts to detect and prevent the financial flows that fuel crime and terrorism more effective. This is crucial, they explain, because it is better to detect and prevent money laundering and terrorist financing than to prosecute it after a crime has occurred.

Mar 8
Mar 8 OCC Revises SCRA Handbook

Adam Witmer

SCRA, Regulatory Update

On 3/4/21, the Office of the Comptroller of the Currency (OCC) issued a revised “Servicemembers Civil Relief Act” booklet, which is part of their larger Comptroller’s Handbook. This revised booklet provides information and procedures for examiners in connection with the consumer protections that servicemembers are eligible for under the Servicemembers Civil Relief Act (SCRA).

Mar 7
Mar 7 Overview Video Added for Fair Lending Bootcamp

Adam Witmer

We have added an overview video that explains what is included in our new Fair Lending Bootcamp. This video runs nearly 10 minutes while Adam explains what is covered in the program and what attendees can expect out of this full-day virtual seminar. The Fair Lending Bootcamp is available on-demand and can be viewed as soon as it is purchased. The new overview video can be viewed at www.compliancecohort.com/fair-lending-bootcamp

Mar 4

Mar 4 VIDEO: What is Disparate Impact

Adam Witmer

Fair Lending

In this Compliance Clip (video), Adam discusses how disparate impact can be discrimination and provides a few examples. This video can be shared with your lending team for training purposes.

Mar 4
Mar 4 New SAR Exemptions! What's the deal?

Adam Witmer

BSA, Regulatory Update

Over the last few months, each of the federal regulators (FDIC, NCUA, OCC, and Federal Reserve) have issued proposals that would permit an exemption from the SAR reporting requirements. Upon first glance, it may appear to some that SARs are no longer required by financial institutions. This, however, is not the case.

Mar 4
Mar 4 CFPB Proposes to Delay New General QM Rule

Adam Witmer

Regulatory Update, Regulation Z

On 3/3/21, the CFPB announced the release of a proposed rulemaking to delay the recently set mandatory compliance date of the General Qualified Mortgage (QM) final rule from July 1, 2021 to October 1, 2022. The CFPB states they are proposing to extend the compliance date to ensure homeowners struggling with the financial impacts of the COVID-19 pandemic have the options they need.

Mar 4
Mar 4 CFPB Sues Payment Processor

Adam Witmer

Regulatory Update

On 3/3/21, the CFPB announced that they had filed a lawsuit against a payment processor and its founder for knowingly processing payments for companies engaged in internet-based technical-support fraud. The CFPB alleges that between 2016 and 2018, Howard and BrightSpeed knowingly processed payments for client companies that purported to offer technical-support services and products over the internet, but instead tricked consumers, often older Americans, into purchasing expensive and unnecessary antivirus software or services.