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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In this Compliance Clip (video), Adam shares some interesting hints of change that relate to overdraft protection programs. While nothing has been formally planned to be changed, this video shows several actions by the regulators which could be a foreshadow to changes with guidance for overdraft protection programs. If your organization has an overdraft protection program, you won’t want to miss this 7 minute video. A transcript of this video is now available.
On 2/2/2022, the OCC issued a bulletin that addresses the OCC’s processes for considering input from state banking commissioners regarding national banks’ performance under state community reinvestment laws, including implementation of community reinvestment-related provisions of the Riegle–Neal Act. The bulletin also addresses expectations regarding the handling of consumer complaints that state officials refer to national banks and federal savings associations, and state referrals of complaints to the OCC.
On 2/2/2022, the CFPB released an article on the hidden cost of junk fees. The CFPB recently launched an initiative to save households billions of dollars a year by reducing exploitative junk fees charged by banks and financial companies.
As we know, one challenge compliance professionals face each year is keeping up with regulatory changes. As part of our jobs, we must figure out what new rules have been passed and then make sure we implement any needed changes in our organizations. That’s the core piece of regulatory change management in a financial institution. But regulatory change management doesn’t stop there: compliance professionals must also be thinking ahead as to what future regulatory changes could be coming down the pike.
In case you missed it, this article is a version of the Compliance Tip Tuesday email we sent you earlier this week. “We have all heard of redlining, but what is digital redlining and how can we look for it in our financial institutions? This article is going to discuss digital redlining and provide some questions we can ask to uncover digital redlining risk in our organizations.”
In this Compliance Clip (video), Adam talks about digital redlining. This is currently a hot topic as the regulators have been focusing their efforts on enforcing fair lending and redlining is one of the things they have been looking into. In this video, Adam describes how digital redlining often relates to disparate impact. A transcript of this video is now available.
On 1/26/2022, the CFPB launched an initiative to save households billions of dollars a year by reducing exploitative junk fees charged by banks and financial companies. This initiative will give the public a chance to share their input in crafting the agency’s rulemaking and guidance agenda, as well as its enforcement priorities in the coming months and years.
On 1/24/2022, the FinCEN issued a Notice of Proposed Rulemaking (NPRM) that proposes and solicits public comment on the establishment of a limited-duration pilot program for sharing suspicious activity reports (SARs), in accordance with Section 6212 of the Anti-Money Laundering Act of 2020. In the pilot program, a financial institution with a SAR reporting obligation would be permitted to share SARs and information related to SARs with foreign branches, subsidiaries, and affiliates for the purpose of combating illicit finance risks, provided FinCEN approves and approves the conditions.
On 1/21/2022, the Federal Financial Institutions Examination Council issued a statement announcing best practices for requesting examination information from supervised entities, and a common authentication solution for secure access to the FFIEC members’ supervision systems. According to FFIEC’s release, the statement presents the results of the final phase of the Examination Modernization Project in which its members addressed the feedback provided by supervised entities regarding examination requests and authentication requirements for its members’ supervision systems.
On 1/21/2022, the FDIC approved a final rule to simplify aspects of the agency’s deposit insurance coverage rules. In particular, deposit insurance coverage for deposits held in connection with irrevocable and revocable trusts is simplified by combining these two deposit insurance categories under one simpler and common calculation.
