CFPB Updates HMDA Coverage Charts

Adam Witmer
Regulatory Update, HMDA

On March 15, 2023, the CFPB published the 2023 HMDA Institutional Coverage Chart  and 2023 HMDA Transactional Coverage Chart. The updated charts are effective January 1, 2023. The updated coverage charts reflect the reduced 25 closed-end loans in each of the previous two calendar years threshold for reporting closed-end applications and loans.

FATF Updates Guidance on Beneficial Ownership of Legal Persons

Paula Parras
BSA, Regulatory Update

On March 10, 2023, the FATF issued the updated Guidance on Beneficial Ownership of Legal Persons will help countries implement the revised requirements of Recommendation 24. In March 2022, the FATF adopted amendments to Recommendation 24, or the Beneficial Ownership of Legal Persons, and its Interpretive Note which require countries to prevent the misuse of legal persons for money laundering or terrorist financing and to ensure that there is adequate, accurate and up-to-date information on the beneficial ownership and control of legal persons.

VIDEO: Required Deposit Disclosure on TIL

VIDEO: Required Deposit Disclosure on TIL

Adam Witmer
Regulation Z

In this Compliance Clip (video), Adam talks about the required deposit disclosure requirements found in Regulation Z if the creditor requires the consumer to maintain a deposit as a condition of the specific transaction. In addition, Adam shares a best practice in managing the required deposit disclosure on TIL. A transcript of this video is now available.

CFPB Finds Unlawful Junk Fees During Supervisory Activities

Adam Witmer
Regulatory Update

On March 8, 2023, the CFPB released a special edition of its Supervisory Highlights that reports on unlawful junk fees uncovered in deposit accounts and in multiple loan servicing markets, including in mortgage, student, and payday lending. The said findings were found during examinations between July 1, 2022, and February 1, 2023. According to the CFPB, these unlawful fees corrode family finances, force up families’ banking and borrowing costs, and are not easily avoided, thus the agency is continuously rooting unlawful fees out of consumer financial markets.

IRS Warns Taxpayers from Filing Fake Returns

Adam Witmer
BSA, Regulatory Update

On March 3, 2023, the IRS issued a consumer alert to warn taxpayers of new scams that urge people to use wage information on a tax return to claim false credits in hopes of getting a big refund. According to the agency, the scheme encourages people to use tax software to manually fill out Form W-2, Wage and Tax Statement, and include false income information to get substantial refunds based on the large amount of withholding.

Agencies Crack Down on Third-Party Intermediaries Used to Evade Russia-Related Sanctions

Adam Witmer
BSA, Regulatory Update

On March 2, 2023, the Department of Commerce, Department of the Treasury, and Department of Justice issued a Tri-Seal Compliance to constrain the use of third-party intermediaries or transshipment points to circumvent restrictions, disguise the involvement of Specially Designated Nationals and Blocked Persons (SDNs) or parties on the Entity List in transactions, and obscure the true identities of Russian end users. The Compliance Note highlights several of these tactics to assist the private sector in identifying warning signs and implementing appropriate compliance measures.

Treasury Sanctions Companies for Timeshare Fraud

Adam Witmer
BSA, Regulatory Update

On March 2, 2023, the OFAC sanctioned eight Mexican companies linked to timeshare fraud on behalf of the Cartel de Jalisco Nueva Generacion (CJNG). A timeshare is a shared ownership model of vacation real estate in which multiple purchasers own allotments of usage in the same property. Timeshare fraud happens when scam artists call sellers of timeshares, posing as a reseller or real estate agent, then claims to have a buyer for the timeshare or guarantees he can sell the timeshare for a good price.

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