FinCEN Begins Changes to Beneficial Ownership Reporting

Adam Witmer
BSA, Regulatory Update

On 4/1/21, the Financial Crimes Enforcement Network (FinCEN) issued an Advance Notice of Proposed Rulemaking (ANPRM) to solicit public comment on a wide range of questions related to the implementation of the beneficial ownership information reporting provisions of the Corporate Transparency Act (CTA). In their release, FinCEN explains that this ANPRM is the first in a series of regulatory actions that FinCEN will undertake to implement the CTA, which is included within the Anti-Money Laundering Act of 2020 (AML Act). The AML Act is part of the FY 2021 National Defense Authorization Act, which became law on January 1, 2021.

NCUA Chairman Named Chairman of FFIEC

Adam Witmer
Regulatory Update

On 4/1/2021, the FFIEC announced that Todd M. Harper, Chairman, National Credit Union Administration (NCUA), was named Chairman of the Federal Financial Institutions Examination Council (FFIEC). His two-year term runs from April 1, 2021, through March 31, 2023. Mr. Harper became the NCUA’s twelfth Chairman on January 20, 2021, and has been making statements over the last year that imply potential changes to how the NCUA will regulate consumer protection going forward.

Revised HMDA Getting It Right Guide for 2021

Adam Witmer
HMDA, Regulatory Update

On 3/31/2021, the FDIC announced that the Federal Financial Institutions Examination Council (FFIEC) had issued the 2021 edition of A Guide to HMDA Reporting: Getting It Right! for Home Mortgage Disclosure Act (HMDA)-related data collected in 2021 and reported in 2022. This longstanding compliance resource has regularly been used by financial institutions as a “go-to” HMDA resource as it can help financial institutions better understand HMDA requirements, including the data collection and reporting provisions.

FDIC Consumer Compliance Supervisory Highlights March 2021 Edition

Adam Witmer
Regulatory Update

On 3/31/2021, the FDIC issued a release (FIL-22-2021) to explain that the latest edition of their Consumer Compliance Supervisory Highlights had been published. The purpose of this publication is to provide insight regarding the FDIC’s consumer compliance supervisory activities and provide a high-level overview of consumer compliance issues identified in 2020 through the FDIC’s supervision of state non-member banks and thrifts. Topics include a summary of the FDIC’s supervisory approach in response to COVID-19, supervisory observations related to consumer protection laws, examples of practices that may be useful to institutions in mitigating risks, regulatory developments, and consumer compliance resources.

Request for Information on AI Use

Adam Witmer
Regulatory Update

On 3/29/21, the Federal Reserve, CFPB, FDIC, NCUA, and OCC jointly released a “Request for Information” to gather insight on financial institutions’ use of artificial intelligence (AI). In their release, the agencies explain that they are seeking information from the public on how financial institutions use AI in their activities, including fraud prevention, personalization of customer services, credit underwriting, and other operations.

UDAAP Foundations Now on Sale!

Adam Witmer

Our UDAAP Foundations class is now on sale with a big discount. This comprehensive UDAAP class runs nearly 3 hours and provides you with everything you need to know regarding one of the highest-risk areas of regulatory compliance - Unfair, Deceptive, and Abusive Acts and Practices. While the program covers the core elements of UDAAP, the best thing about this program may be in Part II of the program where we review over 50 known UDAAP violations! For more information on this program - and to take advantage of the limited time discount on this new program - go to www.compliancecohort.com/udaap-foundations.

CFPB 2020 Report on Complaints Received

Adam Witmer
Regulatory Update

On 3/24/2021, the CFPB announced their 2020 Consumer Response Annual Report to Congress. In their release, the CFPB explains that complaints increased in 2020 due to the impact of the COVID-19 pandemic on the consumer financial marketplace. The CFPB reported handling approximately 542,300 complaints in 2020, which is nearly a 54% increase over the approximately 352,400 complaints handled in 2019.

CFPB Submits Debt Collection Report to Congress

Adam Witmer
Regulatory Update

On 3/22/21, the Consumer Financial Protection Bureau (CFPB) announced the release of its annual report to Congress on the administration of the Fair Debt Collection Practices Act. According to the CFPB’s release, the report highlights efforts by the CFPB and the Federal Trade Commission (FTC) to protect consumers, particularly those who have suffered profound financial impacts due to the COVID-19 pandemic. The CFPB explained that they, along with the FTC and state and federal partners, accomplished much toward stopping unlawful debt collection practices and continuing their vigorous law enforcement, consumer education and public outreach, and policy initiatives.

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