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 explores the topic of flood insurance as it relates to buildings with limited utility or value, focusing on a case involving a construction-to-permanent loan. Using insights from interagency guidelines, Adam clarifies the insurance requirements for properties in flood-prone areas, even when the structures may not hold significant value.
Our BSA Basics class is currently on sale in our store! This program is designed as a higher-level overview of the requirements of a BSA/AML program for banks and credit unions. In just over an hour, you can dive into the basics of BSA/AML training right from the comfort of your office. As you probably know, examiners are on the lookout for BSA officers and relevant staff/management to show their commitment to continuous learning through “outside” training. BSA Basics offers a straightforward and affordable way to meet those expectations. Register or learn more about this program at www.compliancecohort.com/bsa-basics.
On February 19, 2025, FinCEN updated the Alert on its Beneficial Ownership Reporting page stating that beneficial ownership information (BOI) reporting requirements under the Corporate Transparency Act (CTA) are once again back in effect as a result of the decision by the U.S. District Court for the Eastern District of Texas in Smith, et al. v. U.S. Department of the Treasury, et al. However, FinCEN is generally extending the deadline by 30 calendar days from February 19, 2025, for most companies considering that reporting companies may need additional time to comply with their BOI reporting obligations.
The Federal Reserve System recently published its Fourth Issue of Consumer Compliance Outlook for 2024. Consumer Compliance Outlook is the agency’s publication focusing on consumer compliance topics.
Our Winter 2025 Quarterly Compliance Update is now available in our store at an “early bird” price. Our Winter 2025 Quarterly Compliance Update covers all of the regulatory activity that took place during the last quarter of 2024 and is a great way for financial institutions to stay up-to-date on the activity that took place in the regulatory compliance world. Plus, part II of the program focuses on the Reconsideration of Value (ROV) as it relates to appraisals. The special discussion provides an overview of what financial institutions should be aware of and what examiners are saying regarding appraisal bias and the Reconsideration of Value process. Register to our Winter 2025 Quarterly Compliance Update program at www.compliancecohort.com/winter-2025-quarterly-compliance-update.
In this Compliance Clip (video), Adam provides an overview of Reconsideration of Value (ROV) in the context of residential real estate transactions. Drawing on recently released interagency guidance from key financial regulatory bodies, Adam explains the significance of an ROV and the importance of addressing appraisal bias and fair lending concerns.
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.
On February 12, 2025, the NPR reported that dozens of probationary employees at the CFPB had their jobs terminated. CFPB's union has identified approximately 73 "bargaining-unit" employees in their probationary period who were terminated, and believes non-union employees were also fired.
On February 5, 2025, the FDIC released 175 documents related to its supervision of banks that engaged in, or sought to engage in, crypto-related activities. FDIC Acting Chairman Travis Hill said that the release of the documents reflects the Agency’s commitment to enhance transparency.
On February 7, 2025, FDIC Acting Chairman Travis Hill wrote to FinCEN Ddirecto Andrea Gacki expressing his support for updating the Customer Identification Program (CIP) requirements to better align with modern financial services practices. Hill thanked FinCEN and the Department of the Treasury for their collaborative efforts on the issue.
