OCC’s 2023 Annual Report

Paula Parras
Regulatory Update

On December 11, 2023, the OCC issued its annual report to Congress which provides an overview of the condition of the federal banking system. The annual report can be beneficial to compliance professionals as it discusses the OCC's strategic priorities and details agency regulatory and policy initiatives.

OCC’s Fall 2023 Semiannual Risk Perspective

Adam Witmer
Regulatory Update

On December 7, 2023, the OCC released the Fall 2023 edition of its publication Semiannual Risk Perspective. According to the report, economic growth remained solid in the first half of 2023 despite higher interest rates and profitability for the federal banking system also improved even as banks continued to navigate a higher interest rate environment, uncertain economic climate, and fallout from the failure of three regional banks in the spring.

OCC’s Guidance on ‘Buy Now, Pay Later’ Lending

Adam Witmer
Regulatory Update

On December 6, 2023, the OCC issued guidance to national banks and federal savings associations to address the risks associated with “buy now, pay later” lending. The guidance focuses on the risk management of buy now, pay later (BNPL) loans and  notes that banks should maintain underwriting, repayment terms, pricing, and safeguards that minimize adverse customer outcomes. Banks also should ensure that marketing materials and disclosures are clear and conspicuous.

OCC’s Acting Deputy Comptroller Testifies on Financial Technology

Adam Witmer
Regulatory Update

On December 5, 2023, OCC’s Deputy Comptroller for Compliance Policy and Acting Deputy Comptroller for the Office of Financial Technology Donna Murphy today testified on the activities and initiatives of the OCC Office of Financial Technology before the Subcommittee on Digital Assets, Financial Technology and Inclusion, Committee on Financial Services of the U.S. House of Representatives. Ms. Murphy spoke about the OCC's role in monitoring and regulating banks' use of new and emerging technologies.

FDIC Updates Consumer Compliance Exam Manual

Adam Witmer
Regulatory Update

On November 30, 2023, the FDIC updated sections of the Consumer Compliance Examination Manual. The Consumer Compliance Examination Manual is a primary resource and reference tool for FDIC compliance examination staff when conducting Consumer Compliance and CRA examinations. It incorporates examination policies, procedures, and guidance and is available on the FDIC website as a resource for FDIC staff, bankers, and other members of the public.

VIDEO: Leading BSA Board Training

VIDEO: Leading BSA Board Training

Adam Witmer

In this Compliance Clip (video), Adam covers a few best practices to use when conducting BSA training for the Board. As this is often something that is done on an annual basis, BSA training can be repetitive and directors can easily "check out" of the meeting and not have great retention - which defeats the purpose of the meeting. By using best practices in training directors on BSA, your training can be effective, efficient, and even entertaining - which is exactly what your directors want. View this video for a few quick tips on providing BSA training to your board.

FinCEN Extends BOI Reporting Deadline

Adam Witmer
Regulatory Update, BSA

On November 29, 2023, FinCEN issued a final rule that extends the deadline for certain reporting companies to file their initial beneficial ownership information (BOI) reports with FinCEN. Through the final rule, reporting companies created or registered in 2024 will now have 90 calendar days from the date of receiving actual or public notice of their creation or registration becoming effective to file their initial reports.

CFPB Takes Action Against Bank of America for Reporting False Mortgage Data

Adam Witmer
Regulatory Update, HMDA

On November 28, 2023, the CFPB ordered Bank of America to pay a $12 million penalty for submitting false mortgage lending information to the federal government under a long-standing federal law. The CFPB found that hundreds of Bank of America loan officers failed to ask applicants certain demographic questions that are required under federal law, and then falsely reported that the applicants had declined to answer. 

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