On November 7, 2023, the CFPB issued a notice of proposed rulemaking to supervise larger nonbank companies that offer services like digital wallets and payment apps. According to the CFPB, the rule proposed would ensure that these nonbank financial companies adhere to the same rules as large banks, credit unions, and other financial institutions already supervised by the CFPB.

Nov 8
Nov 8 CFPB Fines Citi $25.9 Million for Discrimination Against Armenian Americans

Adam Witmer

Regulatory Update, Fair Lending

On November 8, 2023, the CFPB ordered Citi to pay $25.9 million in fines and consumer redress for intentionally and illegally discriminating against credit card applicants the bank identified as Armenian American. According to CFPB Director Rohit Chopra, Citi purposefully discriminated against applicants of Armenian descent, primarily based on the spelling of their last name, and stereotyped Armenians as prone to crime and fraud. Chopra also said that Citi illegally fabricated documents to cover up its discrimination.

Nov 8
Nov 8 FinCEN Issues Final Rule on Use of FinCEN Identifiers in BOI Reporting

Adam Witmer

BSA, Regulatory Update

On November 7, 2023, FinCEN issued a final rule that specifies the circumstances in which a reporting company may report an entity’s FinCEN identifier in lieu of information about an individual beneficial owner. A FinCEN identifier is a unique number that FinCEN will issue upon request after receiving required information, which will can simplify the reporting process.

Nov 8
Nov 8 FinCEN and BIS Issue New SAR Key Term

Adam Witmer

BSA, Regulatory Update

On November 6, 2023, FinCEN and the BIS issued a new SAR key term to support financial institutions in reporting potential efforts to evade U.S. export controls beyond the Russia-related circumstances that were the focus of those prior two alerts. The new joint notice builds on the success of the two prior alerts issued jointly by the two agencies in generating suspicious activity reporting related to Russia-related export control evasion.

Nov 6
Nov 6 FinCEN Issues Updated FATF Deficient Countries

Adam Witmer

Regulatory Update, BSA

On November 3, 2023, FinCEN issued a press release to inform U.S. financial institutions that the Financial Action Task Force (FATF), an intergovernmental body that establishes international standards to combat money laundering, counter the financing of terrorism, and combat weapons of mass destruction proliferation financing (AML/CFT/CPF), has issued public statements updating its lists of jurisdictions with strategic AML/CFT/CPF deficiencies following its plenary meeting last month. U.S. financial institutions should consider the FATF’s stance toward these jurisdictions when reviewing their obligations and risk-based policies, procedures, and practices.

Nov 6
Nov 6 FDIC Updates its Risk Management Manual of Examination Policies

Adam Witmer

Regulatory Update

In October 2023, the FDIC revised parts of its Risk Management Manual of Examination Policies. The FDIC conducts examinations to help ensure the stability of insured depository institutions by identifying undue risks and weak risk management practices.

Nov 2
Nov 2 OCC Issues Policy Guidance Regarding Venture Loans

Adam Witmer

Regulatory Update

On November 1, 2023, the OCC issued a bulletin to inform banks about policy guidance that applies to commercial loans to early-, expansion-, and late-stage companies, referred to as “venture loans.” The bulletin applies to all OCC-regulated banks, including community banks, that engage in or are considering engaging in venture lending.

Nov 2
Nov 2 OCC Issues Revised TCPA Interagency Exam Procedures

Adam Witmer

Regulatory Update

On November 1, 2023, the OCC published the revised interagency examination procedures for the Telephone Consumer Protection Act (TCPA). The OCC, Federal Deposit Insurance Corporation, and the National Credit Union Administration have revised the interagency examination procedures to reflect amendments to the TCPA that became effective on October 25, 2021.

Nov 1
Nov 1 New Issue of Consumer Compliance Outlook for 2023 Released

Adam Witmer

Regulatory Update

The Federal Reserve System recently published its Second/Third Issue of Consumer Compliance Outlook for 2023. Consumer Compliance Outlook is the agency’s publication focusing on consumer compliance topics.

Oct 30
Oct 30 Texas Judge Puts 1071 Rule on Hold Across US

Adam Witmer

Regulatory Update

On October 26, 2023, the Credit Union Times and Bloomberg reported that the CFPB’s small business lending data collection rule is now on pause nationwide after a Texas federal judge expanded an order that previously applied only to certain banks. In late July 2023, Chief Judge Randy Crane of the US District Court for the Southern District of Texas imposed a preliminary injunction stopping the CFPB from requiring members of the American Bankers Association, Texas Bankers Association, as well as Rio Bank of McAllen, Texas, to comply with the regulation until the Supreme Courts issues its ruling which is expected by June 2024.

Nov 9
Nov 9 CFPB Proposes Rule to Oversee Big tech Companies and Digital Wallets

Nov 8
Nov 8 CFPB Fines Citi $25.9 Million for Discrimination Against Armenian Americans

Nov 8
Nov 8 FinCEN Issues Final Rule on Use of FinCEN Identifiers in BOI Reporting

Nov 8
Nov 8 FinCEN and BIS Issue New SAR Key Term

Nov 6
Nov 6 FinCEN Issues Updated FATF Deficient Countries

Nov 6
Nov 6 FDIC Updates its Risk Management Manual of Examination Policies

Nov 2
Nov 2 OCC Issues Policy Guidance Regarding Venture Loans

Nov 2
Nov 2 OCC Issues Revised TCPA Interagency Exam Procedures

Nov 1
Nov 1 New Issue of Consumer Compliance Outlook for 2023 Released

Oct 30
Oct 30 Texas Judge Puts 1071 Rule on Hold Across US

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