Apr 3
Apr 3 REQUIRED ON MAY 1: Cyber Incident Notification Rule

On May 1, 2022, banks must comply with a new rule to notify their regulators of certain cyber incidents. If your institution isn’t yet ready for this rule, our training program - Cyber Incident Notification Rule 2022 - is designed to help your bank quickly and easily understand the new interagency cyber-incident notification final rule. Our team has spent hours sifting through the new rule to determine what bankers need to know. While our accompanying manual is 38 pages in length - due to us including beneficial background information on the rule - our video presentation breaks down the new rule in an easy to understand format, using layman’s terms. You can learn more about our training program at: www.compliancecohort.com/cyber-incident-notification-rule-2022.

Apr 1

Apr 1 VIDEO: Provisions of RESPA Section 8

Adam Witmer

RESPA

In this Compliance Clip, Adam gives a quick overview of the four provisions of Section 8 of the Real Estate Settlement Procedures Act (RESPA). To better explain how the provisions are incorporated in the regulations, Adam gives a quick visual of the actual law and Regulation X, where the RESPA Section 8 provisions are embedded.

Mar 31
Mar 31 FDIC Requests Comment on Climate-Related Financial Risk Management

Adam Witmer

Regulatory Update

On March 30, 2022, the FDIC issued a request for public comment on draft principles that would provide a high-level framework for the safe and sound management of exposures to climate-related financial risks. The draft principles are intended for the largest financial institutions, those with over $100 billion in total consolidated assets.

Mar 31
Mar 31 FDIC updates Consumer Compliance Exam Manual

Adam Witmer

Regulatory Update

On March 29, 2022, the FDIC updated sections of the Consumer Compliance Examination Manual. The Consumer Compliance Examination Manual is a primary resource and reference tool for FDIC compliance examination staff when conducting Consumer Compliance and CRA examinations. It incorporates examination policies, procedures, and guidance and is available on the FDIC website as a resource for FDIC staff, bankers, and other members of the public.

Mar 30
Mar 30 Agencies Remind of Cyber Notification Requirements

Adam Witmer

Regulatory Update

On March 29, 2022, the FDIC, the Federal Reserve and the OCC issued reminders of their upcoming interagency final rule and provided clarification on the contact information banks must use to them when they experience a cyber notification incident. Starting May 1, 2022, banks regulated by the FDIC, Federal Reserve, or OCC (and their bank service providers) must comply with a new file rule that requires notification to regulators of certain computer-security incidents.

Mar 29
Mar 29 CFPB Extends Deadline for Public Input on Junk Fees

Adam Witmer

Regulatory Update

On March 25, 2022, the CFP announced that it will extend the deadline for the public to share input and stories on their experiences with exploitative junk fees until April 11, 2022. This is after the Bureau received a great amount of feedback from their Request for Information on exploitive junk fees that they issued last January 26, 2022.

Mar 29
Mar 29 FinCEN SAR Filings

Adam Witmer

Regulatory Update, BSA

FinCEN has updated its “SAR Filings by Industry” webpage to include data from 2021. In addition to this webpage, FinCEN has an interactive map and and Interactive SAR Stats which allow BSA professionals to analyze what types of suspicious activity are being reported in their areas. As this data allows specific sorting of the data, BSA professionals are able to sort by many different fields including primary regulator, county, etc.

Mar 28
Mar 28 OFAC Issues New Russia-related Sanctions

Adam Witmer

Regulatory Update

On March 24, 2022, the OFAC designated dozens of Russian defense companies, 328 members of the Russian State Duma, and the head of Russia’s largest financial institution. This is in line with OFAC’s actions to impose severe costs on the Russian Federation for its illegal, unwarranted, and baseless war against Ukraine. The European Union, the United Kingdom, and Canada have also taken similar actions which reflects continued unity to hold Putin accountable for the war that he started.

Mar 25

Mar 25 VIDEO: HMDA Income & Property Value in Credit Decisions

Adam Witmer

HMDA

In this Compliance Clip, Adam answers a HMDA question on whether income and property value should be included in the HMDA LAR when they are not the deciding factor, but are used in determining a credit decision. In other words, when income and property value were factors in the credit decision, but they're just a partial factor, should they be reported?

Mar 23
Mar 23 CFPB Issues Policy Guidance on Consumer Reviews

Adam Witmer

Regulatory Update

On March 22, 2022, the CFPB issued policy guidance regarding potentially illegal practices related to consumer reviews. Through the guidance, the CFPB aims to ensure that customers can write reviews, including those posted online, about financial products and services that accurately reflect their opinions and experiences. The guidance also emphasized that practices such as posting fake reviews or inserting clauses that forbid a customer from publishing an honest review may violate the Consumer Financial Protection Act.