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 discusses whether or not electronic fund transfers (EFTs) that were initiated through fraud or robbery are considered unauthorized EFTs under Regulation E. Adam also cites examples of unauthorized EFTs, based from the CFPB’s FAQs on unauthorized electronic fund transfers. A transcript of this video is now available.
On March 1, 2023, the CFPB released a new issue spotlight examining how the financial products used to deliver public benefits, like Social Security and unemployment compensation, affect individuals’ ability to fully access the assistance provided through those programs. The issue spotlight outlines how governments often choose to deliver public benefits through financial products, particularly prepaid cards, that may subject recipients to high fees and cut into the amount of funds the consumer receives.
On February 27, 2023, the CFPB issued a request for public comment regarding consumer disclosures of a loan that finances both a construction phase and the permanent purchase of a home. The proposal seeks to adjust the existing mortgage disclosures to facilitate the offering of construction and construction-to-permanent loans.
On February 16, 2023, the NCUA approved the final rule on cyber incident reporting requirements during its second open meeting of 2023. The final rule requires a federally insured credit union (FICU) to notify the NCUA as soon as possible, within 72 hours, after it reasonably believes that a reportable cyber incident has occurred.
On February 16, 2023, the CFPB published a summary of its key findings after the Bureau requested information from the largest credit card companies in the U.S. regarding their practices around suppressing actual payment information from the nationwide consumer reporting system. These companies included JPMorgan Chase, Citibank, Bank of America, Capital One, Discover, and American Express.
In this Compliance Clip (video), Adam discusses the timeframe for filing a continuing activity report. The timeframe can be a little bit complicated but the FAQs from FinCEN clarifies the guidance by providing a timeline of activities and Adam tries to simplify it one step further.
On February 9, 2023, the CFPB the CFPB issued Version 1 of the 2023 Reportable HMDA Data: A Regulatory and Reporting Overview Reference Chart. The 38-page chart is intended to be used as a reference tool for data points required to be collected, recorded, and reported under Regulation C.
On February 7, 2023, the OCC published the revised “Branch Closings” booklet of the Comptroller’s Licensing Manual. The revised booklet replaces the June 2017 version where the OCC made corrections where necessary, and contains updated guidance.
Our Compliance Clips have returned! You may have noticed that we haven’t published a new Compliance Clip in the last few weeks. Well, that was due to some technical difficulties, Adam losing his voice, and taxes. Okay, maybe not all of those are fully to blame, but our Compliance Clips are back starting with this one. In this Compliance Clip (video), Adam answers a recent question he received regarding closing a loan on a day that is not considered a business day under the general definition of a business day in Regulation Z.
On February 14, 2023, the Homeland Security Investigations (HSI) launched an awareness campaign to educate the public on dangers associated with online romance scams and how individuals can protect themselves and loved ones.
