On 2/8/2022, the FinCEN announced that the comment period to the notice of proposed rulemaking (NPRM) requiring the reporting of beneficial ownership information (BOI), tagged as Reporting NPRM, has closed. FinCEN received at least 230 comments. The next step in the CTA rulemaking series will be the publication of proposed rules on BOI access and disclosure requirements, which will be known as the “Access NPRM”, and which the FinCEN plans to publish later this year.

The enrollment period for our premium memberships will be ending next week. Premium memberships are a great way for compliance professionals to stay up-to-date with regulatory changes while getting many of our training programs at a bundled price. Plus, we are offering a new membership plan for 2022: Premium Pro. Premium Pro is the first “access all” type of plan we have ever offered where members get access to everything in our store - and everything new we release during the year. Yep. All of our training programs we offer at one low, bundled price. And, new in 2022 is an added benefit called Premium Perks where premium members enjoy additional tools like executive summaries and special training videos. Enrollment for all three premium membership options only happens twice a year (Jan/Feb & July/Aug) and the current enrollment period will be ending next week. Take a look at everything included in our premium membership options at: www.compliancecohort.com/premium-membership.

VIDEO: Are Changes Coming to Overdraft Programs?

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.

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.”