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On March 28, 2025, the FDIC rescinded FIL-16-2022 and provided new guidance for FDIC-supervised institutions engaging or seeking to engage in crypto-related activities.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.

Mar 27
Mar 27 CFPB Seeks to Overturn Case Against Townstone

Adam Witmer

Fair Lending, Regulatory Update

On March 26, 2025, the CFPB announced that it is seeking to vacate the settlement the CFPB extracted from Townstone back in 2024 after suing the nonbank retail-mortgage creditor for discriminatory lending practices and redlining. In its press release, the CFPB stated that after a thorough review, the Bureau is seeking to “make Townstone whole by returning the six-figure penalty they were forced to pay.”

Mar 25
Mar 25 FinCEN Publishes FAQs on the Southwest Border GTO

Adam Witmer

Regulatory Update, BSA

On March 24, 2025, FinCEN issued a set of Frequently Asked Questions for the Geographic Targeting Order involving certain money services businesses in California and Texas on the Southwest Border. This is in relation to the March 11 GTO requiring all money services businesses located in 30 ZIP Codes across California and Texas to file additional Currency Transaction Reports (CTRs) with FinCEN for transactions above $200 but not more than $10,000.

Mar 24
Mar 24 FinCEN Removes BOI Reporting Requirements for U.S. Entities

Adam Witmer

BSA, Regulatory Update

On March 21, 2025, FinCEN issued an interim final rule that removes the requirement for U.S. companies and U.S. persons to report beneficial ownership information (BOI) to FinCEN under the Corporate Transparency Act. Foreign entities that meet the new definition of a “reporting company” and do not qualify for an exemption must report their BOI to FinCEN under new deadlines.

Mar 18
Mar 18 FinCEN Issues GTO Imposing Additional Reporting Requirements Along the Southwest Border

Adam Witmer

Regulatory Update, BSA

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.

Mar 17
Mar 17 OCC Reaffirms That Certain Crypto-Asset Activities Are Permissible

Adam Witmer

Regulatory Update

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.

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

Mar 27
Mar 27 CFPB Seeks to Overturn Case Against Townstone

Mar 25
Mar 25 FinCEN Publishes FAQs on the Southwest Border GTO

Mar 24
Mar 24 FinCEN Removes BOI Reporting Requirements for U.S. Entities

Mar 18
Mar 18 FinCEN Issues GTO Imposing Additional Reporting Requirements Along the Southwest Border

Mar 17
Mar 17 OCC Reaffirms That Certain Crypto-Asset Activities Are Permissible

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