All by Adam Witmer

FDIC Withdraws Four Proposed Rules

Adam Witmer
Regulatory Update

On 3/3/25, the FDIC announced that it was withdrawing three proposed rules relating to brokered deposits, corporate governance, and the Change in Bank Control Act (CBCA). The FDIC also announced a withdraw of the authority previously approved by the FDIC Board of Directors to publish a proposed rule on incentive-based compensation arrangements.

FinCEN Announces No Fines for BOI Deadline Violations

Adam Witmer
BSA, Regulatory Update

On 2/27/25, FinCEN announced that it will not impose fines, penalties, or any other enforcement actions against companies that fail to file or update beneficial ownership information (BOI) reports under the Corporate Transparency Act by the current deadlines. In a news release, FinCEN stated that “no fines or penalties will be issued, and no enforcement actions will be taken, until a forthcoming interim final rule becomes effective and the new relevant due dates in the interim final rule have passed.”

EARN CEs: Winter 2025 Quarterly Compliance Update

Adam Witmer

Earn 5.0 CRCM/CERP, 0.5 CAFP continuing education credits with our Winter 2025 Quarterly Compliance Update. This program 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. This section of our program is a great way to get current on what the regulators have been saying as it relates to appraisal bias and ROV expectations. You can learn more about our Winter 2025 Quarterly Compliance Update at www.compliancecohort.com/winter-2025-quarterly-compliance-update.

VIDEO: Reg E Dispute Involving a Previous Merchant

VIDEO: Reg E Dispute Involving a Previous Merchant

Adam Witmer
Regulation E

In this Compliance Clip (video), Adam responds to a question about how to handle disputes involving a merchant that a consumer has previously used. He explains whether financial institutions can deny a dispute solely based on a customer's history with that merchant, highlighting the requirements set forth by Regulation E.

EARN CEs: UDAAP Bootcamp

Adam Witmer

Earn 5.5 CRCM, CERP, CFMP continuing education credits with our UDAAP Bootcamp. Our UDAAP Bootcamp program provides you with foundational training about Unfair, Deceptive, or Abusive Acts or Practices (UDAAP) as well as helps you know what to look for in your organization. This class covers two main areas. The program starts with a history and overview of UDAAP guidance while it concludes by covering a good number of known UDAAP violations - which attendees can essentially use as a checklist to make sure their organizations are free from many known UDAAP issues that have been cited as violations in other organizations. Plus, this program is currently on sale. To register for our UDAAP Bootcamp program, go to www.compliancecohort.com/udaap-bootcamp.

FinCEN Reminder on Relationship Investment Scams

Adam Witmer
BSA, Regulatory Update

On 2/26/25, FinCEN issued an advisory to remind financial institutions to remain vigilant regarding suspicious activity that may be indicative of relationship investment scams. This alert was issued in support of the multiagency #DatingOrDefrauding Campaign launched by the Commodity Futures Trading Commission to alert the public to relationship investment scams targeting Americans through wrong-numbered texts, dating apps, and social media. The advisory states that losses from romance and confidence scams reported to the Federal Bureau of Investigation exceeded $650 million in 2023.

FATF Updates List of Deficient Countries (2/26/25)

Adam Witmer
BSA, Regulatory Update

On February 26, 2025, FinCEN released an advisory on the FATF-identified jurisdictions with AML/CFT/CPF deficiencies. In this latest update, the FATF added Laos and Nepal to the list of Jurisdictions Under Increased Monitoring and removed the Philippines. The list of High-Risk Jurisdictions Subject to a Call for Action remains unchanged, with Iran, North Korea (DPRK), and Burma still subject to FATF’s highest level of scrutiny. Specifically, FATF continues to call for countermeasures against Iran and DPRK, while Burma remains subject to enhanced due diligence.

Treasury Summarizes FATF Prenary

Adam Witmer
BSA, Regulatory Update

On 2/21/25, the US Department of Treasury reported that the Financial Action Task Force (FATF) concluded a plenary in Paris, where Treasury representatives participated in discussions on proliferation and terrorist financing risks, financial inclusion, and payment standards, leading to draft updates for public consultation. The Treasury also reported that FATF launched a public consultation on sanctions evasion schemes and endorsed changes to its recommendations to reinforce a risk-based approach to combating illicit finance, including ensuring preventive or mitigation measures are commensurate with the risks identified.

OFAC Launches New File Finder Application

Adam Witmer
BSA, Regulatory Update

On 2/20/25, OFAC launched a new “File Finder” application for use on its website. The application is browser-based and allows “users to search through and efficiently navigate all of OFAC’s website content,” according to a release by OFAC. OFAC explains that the new application “searches all static content on OFAC's website (PDF documents, word documents, etc.) by document title, document type, and the contents of each document. Searchable content typically includes general licensees, federal register notices, executive orders (and other legal documents), press charts, advisories, specific guidance, as well as many other records.”

VIDEO: Flood Insurance for Buildings With Limited Utility or Value

VIDEO: Flood Insurance for Buildings With Limited Utility or Value

Adam Witmer
Flood

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.

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