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.
If you haven't done so already, make sure you sign up for our free membership where you get access to many member-only videos, articles, and other resources.
In this Compliance Clip (video), Adam explains the nuances of authorized but fraudulent debit card transactions. He discusses the distinctions in liability for consumers when a scammer initiates a transaction versus when the consumer unknowingly authorizes it.
Our Appraisal Compliance Requirements class is currently on sale in our store. This program is designed to cover the key compliance elements related to appraisals and evaluations. Our Appraisal Compliance Requirements program includes a quick review of the appraisal requirements found in Regulation B & Regulation Z, a review of the key elements of the interagency guidance on appraisal standards focusing on the compliance elements, and a full section on appraisal bias. The last section also includes a quick discussion on fair lending and provides a list of best practices financial institutions can take to mitigate fair lending risk as it relates to appraisals and evaluations. To enroll in our Appraisal Compliance Requirements class, go to www.compliancecohort.com/appraisal-compliance-requirements.
On March 11, 2025, FinCEN issued a notice of a Geographic Targeting Order requiring certain money services businesses along the southwest border of the United States to report and retain records of transactions in currency of more than $200 but not more than $10,000, and to verify the identity of persons presenting such transactions. The order will take effect starting April 14, 2025 and ends on September 9, 2025.
On March 7, 2025, the OCC issued a letter to reaffirm that a range of cryptocurrency activities are permissible in the federal banking system. Through Interpretive Letter 1183, the OCC confirmed that crypto-asset custody, certain stablecoin activities, and participation in independent node verification networks such as distributed ledger are permissible for national banks and federal savings associations.
On March 5, 2025, the Senate issued a joint resolution (S.J.Res. 28) disapproving the rule submitted by the CFPB relating to “Defining Larger Participants of a Market for General-Use Digital Consumer Payment Applications”. The CFPB finalized the rule in November 2024 which aimed to supervise the largest nonbank companies offering digital funds transfer and payment wallet apps.
If you are looking for a Regulation E training that focuses only on the error resolution and consumer liability sections of Regulation E rather than all parts of the rule, this program is for you. Our Regulation E Error Resolutions class helps attendees understand their responsibilities for consumer liability and error resolutions as they relate to Re E. To accomplish this, our program contains four parts: a brief introduction and discussion of a few key definitions; a review of consumer liability provisions of Reg E; a discussion of the error resolution requirements; and a review of a number of CFPB’s FAQs. To see the full curriculum and watch the overview of this program, go to www.compliancecohort.com/reg-e-error-resolutions.
In this Compliance Clip (video), Adam discusses the nuances of adverse action notices in the context of declined counteroffers for commercial loans. He explains the regulatory framework under Regulation B and the implications for lenders when an applicant withdraws their application after a counteroffer is declined.
Our Regulation E Bootcamp is currently on sale in our store. Our Regulation E Bootcamp is designed to review the requirements of the Electronic Fund Transfer Act (EFTA), as implemented by Regulation E, including a deep dive into the liability and error resolution rules. The goal of this program is to cover the main elements of Regulation E that would apply to your organization while spending extra time on the areas that have the greatest risk for non-compliance. You can register for this program at www.compliancecohort.com/regulation-e-bootcamp.
Our 2024 FDIC Official Signs & Advertising Final Rule is currently on sale in our store. Our FDIC Advertising Rules class is designed to equip financial professionals with an understanding of the final rule of the new FDIC advertising and how it will affect their banks. The program includes an introduction and background of the FDIC’s official signs and advertising of membership rules, a review of Subpart A of the FDIC final rule in detail, and the elements of Subpart B that changed in the final rule. This new FDIC rule is going to be extremely important for banks to pay attention to as the rule saw several significant updates for current technology and electronic delivery channels. To learn more and register for our 2024 FDIC Official Signs & Advertising Final Rule, go to www.compliancecohort.com/2024-fdic-final-rule.
In this Compliance Clip (video), Adam discusses the critical concept of "permissible purpose" when obtaining credit reports under the Fair Credit Reporting Act (FCRA). Understanding these guidelines is essential for lenders and creditors to avoid significant legal violations and breaches of privacy.
