FinCEN to Hold Ransomware Event

Adam Witmer
BSA, Regulatory Update

On 7/15/2021, the Financial Crimes Enforcement Network (FinCEN) announced it will hold an event in August 2021 with representatives from financial institutions, other key industry stakeholders, and federal government agencies to discuss ongoing concerns regarding ransomware, as well as efforts by the public and private sectors. In their release, FinCEN explained that this event will build upon their November 2020 event on ransomware. FinCEN anticipates that this event, being referenced as a “FinCEN Exchange”, will assist its government and private sector partners to inform next steps to address ransomware and focus resources to mitigate the threat. This announcement is part of a whole-of-government effort to combat ransomware.

Proposed Guidance for Third-Party Releationships

Adam Witmer
Regulatory Update, Compliance Management

On 7/13/21, the joint agencies (Federal Reserve, FDIC, & OCC) announced a request for public comment on proposed guidance designed to help banking organizations manage risks associated with third-party relationships, including relationships with financial technology-focused entities. Comments must be received within 60 days of the proposed guidance's publication in the Federal Register.

FHFA Publishes Policy Statement on Fair Lending

Adam Witmer
Fair Lending, Regulatory Update

On 7/1/2021, the Federal Housing Finance Agency issued a policy statement on Fair Lending to communicate the agency's general position on monitoring and information gathering, supervisory examinations, and administrative enforcement related to the Equal Credit Opportunity Act, the Fair Housing Act, and the Federal Housing Enterprises Financial Safety and Soundness Act. The FHFA is also soliciting comments on its application.

FinCEN Issues Updated FATF Deficient Countries

Adam Witmer
BSA, Regulatory Update

On July 1, 2021, the Financial Crimes Enforcement Network (FinCEN) issued a news release to announce updates to the FATF list of jurisdictions with strategic anti-money laundering and combating the financing of terrorism and counter-proliferation financing deficiencies. As updates to the FATF list were previously issued as advisories, FinCEN explained that this news release should be treated the same way as prior advisories - implying that future updates to the FATF list will continue to come as news releases rather than advisories.

FinCEN Issues National AML Priorities

Adam Witmer
BSA, Regulatory Update

On 6/30/2021, the Financial Crimes Enforcement Network (FinCEN) issued a set of government-wide priorities for anti-money laundering and countering the financing of terrorism policy. The Priorities identify and describe the most significant AML/CFT threats currently facing the United States and include: corruption, cybercrime, domestic and international terrorist financing, fraud, transnational criminal organizations, drug trafficking organizations, human trafficking and human smuggling, and proliferation financing. FinCEN also issued two statements to provide guidance to covered institutions on how to approach the Priorities.

New FFIEC IT Booklet

Adam Witmer
Regulatory Update

On 6/30/2021, the CFPB announced that the Federal Financial Institutions Examination Council (FFIEC) issued a new IT booklet titled “Architecture, Infrastructure, and Operations.” According to the CFPB release, the booklet provides expanded guidance to help financial institution examiners assess the risk profile and adequacy of an entity’s information technology architecture, infrastructure, and operations.

CFPB Issues Summer 2021 Edition of Supervisory Highlights

Adam Witmer
Regulatory Update

On 6/29/2021, the CFPB released a new issue of their publication, Supervisory Highlights. In this edition, the CFPB provides a report highlighting legal violations identified by the Bureau’s examinations in 2020. The report also highlights prior CFPB supervisory findings that led to public enforcement actions in 2020 resulting in more than $124 million in consumer remediation and civil money penalties.

FDIC & Federal Reserve List of 2021 Distressed or Underserved Non-Metro Middle-Income Geographies

Adam Witmer
Regulatory Update

On 6/25/2021, the FFIEC announced that both the Federal Reserve and the FDIC announced the availability of the 2021 list of distressed or underserved nonmetropolitan middle-income geographies. These are geographic areas where revitalization or stabilization activities are eligible to receive Community Reinvestment Act (CRA) consideration under the community development definition.

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