OFAC’s New Website

Adam Witmer
Regulatory Update

On April 3, 2023, the OFAC launched its new website at ofac.treasury.gov. The OFAC’s new website includes new functionalities such as a new streamlined landing page, enhanced Frequently Asked Questions (FAQs) search, sanctions program filter, recent actions information embedded in each sanctions page, and a new “mega menu” interface.

CFPB Issues Guidance Regarding Abusive Conduct in Financial Markets

Adam Witmer
Regulatory Update

On April 3, 2023, the CFPB issued a policy statement that explains the legal prohibition on abusive conduct in consumer financial markets and summarizes over a decade of precedent. The policy statement details post-financial crisis prohibition on illegal abusive conduct. It aims to assist consumer financial protection enforcers in identifying wrongdoing, and will help firms avoid committing abusive acts or practices.

1071 Resources Available NOW and Coming Soon!

Adam Witmer
Regulation B

On 3/30/23, the CFPB released the long anticipated rule that implements section 1071 of the Dodd-Frank Act. This rule will require certain lenders to report information about the small business credit applications they receive, including geographic and demographic data, lending decisions, and the price of credit. As you would expect, we are working on a number of resources to assist our members in understanding if this rule applies to them and, if so, help them implement this rule within their organizations. Click the link to this article to see the 1071 resources we currently have available as well as those we are working to create.

FDIC Consumer Compliance Supervisory Highlights March 2023 Edition

Adam Witmer
Regulatory Update

On April 5, 2023, the FDIC issued the March 2023 edition of the Consumer Compliance Supervisory Highlights. The purpose of this publication is to enhance transparency regarding the FDIC’s consumer compliance supervisory activities and to provide a high-level overview of consumer compliance issues identified in 2022 through the FDIC’s supervision of state non-member banks and thrifts.

FRB Fines Wells Fargo For Inadequate Oversight of Sanctions Risk

Adam Witmer
Regulatory Update

On March 30, 2023, the Federal Reserve Board announced that it has fined Wells Fargo & Company $67.8 million for the firm's unsafe or unsound practices relating to historical inadequate oversight of sanctions compliance risks at its subsidiary bank, Wells Fargo Bank, N.A. Wells Fargo & Co.'s deficient oversight enabled the bank to violate U.S. sanctions regulations by providing a trade finance platform to a foreign bank that used the platform to process prohibited transactions.

CFPB Releases 1071 Rule

Adam Witmer
Regulation B

On 3/30/23, the CFPB released the long anticipated rule that implements section 1071 of the Dodd-Frank Act. This rule will require certain lenders to report information about the small business credit applications they receive, including geographic and demographic data, lending decisions, and the price of credit. As this rule was just released, we will be analyzing this rule and providing further guidance in the near future. That said, the CFPB provided several key elements in their release which you can view by clicking the link to to this article and going to our site. If you would like to get on our wait list to receive updates about resources we create (both free of paid) relating to the 1071 final rule, go to https://www.compliancecohort.com/1071-wait-list.

FinCEN Publishes Initial BOI Reporting Guidance

Adam Witmer
Regulatory Update

On March 24, 2023, FinCEN published its first set of guidance materials to aid the public, and in particular the small business community, in understanding upcoming beneficial ownership information (BOI) reporting requirements taking effect on January 1, 2024. The new regulations require many corporations, limited liability companies, and other entities created in or registered to do business in the United States to report information about their beneficial owners to FinCEN.

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