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 talks about a policy guidance that the CFPB issued on March of 2022. Specifically, the policy guidance provides information about potentially illegal practices relating to consumer reviews and how these may lead to violations of the Consumer Financial Protection Act. A transcript of this video is now available.
On May 11, 2022, five federal regulatory agencies jointly issued revised questions and answers (Q&As) regarding federal flood insurance law and the agencies’ implementing regulations. The Q&As supersede those originally published by the agencies in 2009 and 2011 as well as consolidate Q&As proposed by the agencies in 2020 and 2021. The revised Q&As also include the changes to the flood insurance requirements made by federal law in recent years. We plan to release a training program coving the Flood FAQs during the summer of 2022, so contact us with more information regarding this future program.
On May 9, 2022, the CFPB issued an Advisory Opinion to affirm that the Equal Credit Opportunity Act and Regulation B protect not only those actively seeking credit but also those who sought and have received credit. ECOA is a civil rights law that protects individuals and businesses against discrimination in accessing and using credit on the basis of race, color, religion, national origin, sex, marital status, age.
On May 5, 2022, the federal bank regulatory agencies issued a joint proposal to strengthen and modernize regulations implementing the Community Reinvestment Act (CRA) to better achieve the purposes of the law. CRA is a landmark law that encourages banks to help meet the credit needs of their local communities, including low- and moderate-income (LMI) neighborhoods, in a safe and sound manner.
In this Compliance Clip, Adam discusses one of the topics that is included in our Spring 2022 Quarterly Compliance Update, that is - the CFPB found lenders discriminating against applicants based on religious beliefs. While discrimination based on religion has long been prohibited, Adam explains that release by the CFPB show us a trend in fair lending that all financial institutions should be ready for. In addition, the CFPB also expressed its concern about digital redlining, a topic that Adam also talked about in another Compliance Clip. A transcript of this video is now available.
On May 3, 2022, the FHFA announced that Fannie Mae and Freddie Mac will require lenders to use the Supplemental Consumer Information Form (SCIF) as part of the application process for loans that will be sold to the said Enterprises. The purpose of the SCIF is to collect information about the borrower's language preference, if any, and on any homebuyer education or housing counseling the borrower received, to help lenders facilitate communications with borrowers in their preferred language. Lenders will be required to adopt these changes and reporting requirements for loans with application dates on or after March 1, 2023.
On May 2, 2022, the CFPB published an article to highlight its initiative in ensuring a fair, transparent, and competitive auto lending market, including taking action against sloppy servicing practices that cause harm. As we published previously, the Bureau released a bulletin in late February which aims to mitigate illegal automobile repossessions.
On April 29, 2022, the FSB published a report that aims to assist supervisory and regulatory authorities in developing their approaches to monitor, manage and mitigate cross-sectoral and system-wide risks arising from climate change and to promote consistent approaches across sectors and jurisdictions.
On May 2, 2022, the CFPB released an article on how to prevent and report scams targeting older adults. In partnership with the Federal Trade Commission, the CFPB aims to help older adults and their families and friends know what to do if someone demands payment by these methods, and where to report fraud.
On April 29, 2022, FinCEN announced the renewal and expansion of its Geographic Targeting Orders (GTOs) that require U.S. title insurance companies to identify the natural persons behind shell companies used in all-cash purchases of residential real estate. The terms of the GTOs are effective beginning April 30, 2022, and ending on October 26, 2022.
