FinCEN Director Gacki Discusses FinCEN Initiatives at the ACAMS

Adam Witmer
Regulatory Update

On October 3, 2023, FinCEN Director Andrea Gacki spoke at the The Assembly by ACAMS where she enumerated FinCEN’s present priorities in terms of combatting financial crimes. In particular, Gacki discussed the agency’s updates on Beneficial Ownership Information implementation, anti-Corruption initiatives in the residential real estate and investment, efforts to combat fentanyl trafficking, and proposed whistleblower program.

VIDEO: Denial Reasons for Not Meeting a Minimum Credit Score

VIDEO: Denial Reasons for Not Meeting a Minimum Credit Score

Adam Witmer
Regulation B, Adverse Action

In this Compliance Clip (video), Adam discusses what denial reasons should be used when an applicant does not meet a minimum credit score. He explains that there are sometimes reasons that are easily listed on the Adverse Action notice, but other times, the reasons for a low credit score may not be as clear. If your financial institution has a minimum credit score requirement, this video is a must watch.

FRB’s FedNow Service Reports Growth in Participation

Adam Witmer
Regulatory Update

On October 3, 2023, announced that the FedNow Service has experienced strong growth following its launch in July, with 108 institutions now sending and receiving on the network. According to the Federal Reserve’s press release, 21 financial institutions are providing liquidity and settlement services, and 20 service providers are supporting payment processing in the instant payments infrastructure.

FinCEN Proposes Changes to the BOI Reports

Adam Witmer
Regulatory Update, BSA

On September 29, 2023, the Department of the Treasury published through the Federal Register a Notice of information collection, that the Agency will submit to the Office of Management and Budget (OMB) for review and clearance in accordance with the Paperwork Reduction Act of 1995 (PRA). The request for information is in relation to the BOIR Form. The public is invited to submit comments on this information collection request on or before October 30, 2023.

OCC’s 2024 Bank Supervision Operating Plan

Adam Witmer
Regulatory Update

On September 28, 2023, the OCC released its bank supervision operating plan for fiscal year 2024, which begins on October 1, 2023 and ends on September 30, 2024. The plan provides the foundation for policy initiatives and for supervisory strategies as applied to individual national banks, federal savings associations, federal branches, federal agencies, and technology service providers. The OCC staff will use this plan to guide their supervisory priorities, planning, and resource allocations.

FinCEN Publishes BOI Brochure

Adam Witmer
Regulatory Update

FinCEN recently published a brochure titled An Introduction to Beneficial Ownership Information Reporting as a quick reference to the BOI final rule. The brochure serves as a quick reference on the requirements for who, how, and when to report to FinCEN for beneficial ownership information.

FinCEN Proposes to Extend Filing Deadline for Certain BOI Reports

Adam Witmer
Regulatory Update, BSA

On September 28, 2023, FinCEN published through the Federal Register Notice of Proposed Rulemaking which seeks to amend the beneficial ownership information (BOI) reporting rule to extend the deadline to file initial BOI reports for entities created or registered on or after the rule's effective date of January 1, 2024, and before January 1, 2025. While this rule likely won't affect financial institutions directly, it will have a direct impact on business entity customers.

CFPB Proposes Rule Removing Medical Bills from Credit Reports

Adam Witmer
Regulatory Update, FCRA

On September 21, 2023, the CFPB announced it is beginning a rulemaking process to remove medical bills from Americans’ credit reports. The CFPB outlined proposals under consideration that would help families financially recover from medical crises, stop debt collectors from coercing people into paying bills they may not even owe, and ensure that creditors are not relying on data that is often plagued with inaccuracies and mistakes.

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