On April 1, 2025, FinCEN issued an Advisory to assist financial institutions in identifying and reporting suspicious activity related to the financing of the Islamic State of Iraq and Syria (ISIS). The Advisory outlines how ISIS funds itself through international support and various money transfer methods and also provides red flags for financial institutions to identify suspicious activity.

Apr 7
Apr 7 FDIC Updates Risk Manual of Exam Policies

Adam Witmer

Regulatory Update

On March 27, 2025, the FDIC released an update to its Risk Management Manual of Examination Policies. In particular, the section “Other Assets and Liabilities” was updated.

Apr 4

Apr 4 VIDEO: What is the 6% cap under SCRA

Paula Parras

SCRA

In this Compliance Clip (video), Adam discusses the 6% interest rate cap under the Servicemember Civil Relief Act (SCRA) and how it benefits active-duty military personnel. As interest rates continue to rise, understanding these protections becomes increasingly important for creditors. A transcript of this video is now available.

Apr 4
Apr 4 ENTER TO WIN: Fair Lending Bootcamp!

Adam Witmer

In case you missed our announcement earlier this week, we are giving away one enrollment to our Fair Lending Bootcamp. Our Fair Lending Bootcamp is designed as a full-day virtual seminar, that takes an in-depth look at what financial institutions need to consider in regards to fair lending. The program includes an introduction to fair lending, a review of Regulation B, a look at some of the applicable aspects of the Fair Housing Act, and a review of fair lending risk indicators. The program even discusses a few fair lending hot topics. The full curriculum for our Fair Lending Bootcamp can be found at www.compliancecohort.com/fair-lending-bootcamp. To join the giveaway, just complete a short entry form at www.compliancecohort.com/entry-april-2025. The full contest rules can be found here.

Apr 3
Apr 3 OCC Withdraws Climate Risk Principles for Large Financial Institutions

Adam Witmer

Regulatory Update

On March 31, 2025, the OCC withdrew its participation in the interagency principles for climate-related financial risk management for large financial institutions. In a statement, Acting Comptroller of the Currency Rodney E. Hood said “the principles providing guidance to banks for climate-related financial risk are overly burdensome and duplicative.”

Apr 1
Apr 1 CFPB Announces Availability of 2024 Mortgage Lending HMDA Data

Adam Witmer

HMDA, Regulatory Update

On March 28, 2025, the CFPB announced that the HMDA Modified Loan Application Register (LAR) data for 2024 are now available on the FFIEC’s HMDA Platform for approximately 4,898 HMDA filers. The published data contain loan-level information filed by financial institutions and modified to protect consumer privacy.

Apr 1
Apr 1 FinCEN Issues Alert on Bulk Cash Smuggling by Mexico TCOs

Adam Witmer

BSA, Regulatory Update

On March 31, 2025, FinCEN issued an Alert on bulk cash smuggling and repatriation by Mexico-based Transnational Criminal Organizations (TCOs). The Treasury, alongside FinCEN, is urging financial institutions to be vigilant in identifying and reporting transactions potentially related to the cross-border smuggling of bulk cash from the United States into Mexico and the repatriation of bulk cash into the U.S. and Mexican financial systems by these Mexico-based criminal organizations.

Apr 1
Apr 1 FDIC Issues Guidance on Banks’ Crypto-Related Activities

Adam Witmer

Regulatory Update

On March 28, 2025, the FDIC rescinded FIL-16-2022 and provided new guidance for FDIC-supervised institutions engaging or seeking to engage in crypto-related activities. FIL-16-2022, titled Notification of Engaging in Crypto-Related Activities, established a prior notification requirement for FDIC-supervised institutions that wish to engage in crypto-related activities.

Mar 31
Mar 31 Senate Votes to Overturn CFPB’s Overdraft Lending Final Rule

Adam Witmer

Regulatory Update

On March 28, 2025, the ABA Banking Journal reported that Senate has voted in favor of a resolution to overturn the CFPB’s limit on overdraft fees. On December 12, 2024, the CFPB amended Regulations E and Z to update rules for overdraft credit offered by very large banks.

Mar 31
Mar 31 OCC Removes Reputation Risk from Bank Examinations

Adam Witmer

Regulatory Update

On March 20, 2025, the OCC issued a Bulletin announcing that it has commenced removing references to banks' reputation risk from its Comptroller’s Handbook booklets and guidance issuances. Concurrently, the OCC has instructed its examiners that they should no longer examine for reputation risk.

Apr 7
Apr 7 FinCEN Issues Advisory on the Financing of ISIS

Apr 7
Apr 7 FDIC Updates Risk Manual of Exam Policies

Apr 4 VIDEO: What is the 6% cap under SCRA

Apr 4
Apr 4 ENTER TO WIN: Fair Lending Bootcamp!

Apr 3
Apr 3 OCC Withdraws Climate Risk Principles for Large Financial Institutions

Apr 1
Apr 1 CFPB Announces Availability of 2024 Mortgage Lending HMDA Data

Apr 1
Apr 1 FinCEN Issues Alert on Bulk Cash Smuggling by Mexico TCOs

Apr 1
Apr 1 FDIC Issues Guidance on Banks’ Crypto-Related Activities

Mar 31
Mar 31 Senate Votes to Overturn CFPB’s Overdraft Lending Final Rule

Mar 31
Mar 31 OCC Removes Reputation Risk from Bank Examinations

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