On March 29, 2024, FinCEN issued a notice and request for information and comment regarding the Customer Identification Program (CIP) Rule requirement for banks to collect a taxpayer identification number (TIN), among other information, from a customer who is a U.S. person, prior to opening an account. Specifically, FinCEN seeks information to understand the potential risks and benefits, as well as safeguards that could be established, if banks were permitted to collect partial SSN information directly from the customer for U.S. individuals and subsequently use reputable third-party sources to obtain the full SSN prior to account opening.

Apr 1
Apr 1 FDIC Consumer Compliance Supervisory Highlights March 2024 Edition

Adam Witmer

Regulatory Update

On March 28, 2024, the FDIC issued the March 2024 edition of the Consumer Compliance Supervisory Highlights. The purpose of this publication is to enhance transparency regarding the FDIC’s consumer compliance supervisory activities and to provide a high-level overview of consumer compliance issues identified in 2023 through the FDIC’s supervision of state non-member banks and thrifts.

Apr 1
Apr 1 FDIC Updates its Consumer Compliance Exam Manual

Adam Witmer

Regulatory Update

On March 28, 2024, the FDIC updated sections of the Consumer Compliance Examination Manual. The Consumer Compliance Examination Manual is a primary resource and reference tool for FDIC compliance examination staff when conducting Consumer Compliance and CRA examinations. It incorporates examination policies, procedures, and guidance and is available on the FDIC website as a resource for FDIC staff, bankers, and other members of the public.

Mar 28
Mar 28 CFPB Announces Availability of 2023 Mortgage Lending HMDA Data

Adam Witmer

Regulatory Update

On March 27, 2024, the CFPB announced that the HMDA Modified Loan Application Register (LAR) data for 2023 are now available on the FFIEC’s HMDA Platform for approximately 5,089 HMDA filers. The published data contain loan-level information filed by financial institutions and modified to protect consumer privacy.

Mar 28
Mar 28 CFPB, Federal and State Agencies Issue Statements on Tech & Enforcement

Adam Witmer

Regulatory Update

On March 26, 2024, the federal and state agencies, CFPB, released agency-specific action statements on tech capacity. According to the CFPB press release, these statements reflect concrete actions to increase tech capacity to help enforce the laws on the book and design remedies that work for consumers, workers, small businesses, and others in the digital era.

Mar 28
Mar 28 FATF Highlights Treasury's Anti-Financial Crime Initiatives

Adam Witmer

Regulatory Update, BSA

On March 26, 2024, the FATF announced that the United States has been upgraded to “largely compliant” with FATF Recommendation 24, which relates to beneficial ownership transparency for legal persons. FATF is the global standard-setting body for anti-money laundering, countering the financing of terrorism, and countering proliferation financing (AML/CFT/CPF).

Mar 27
Mar 27 HUD Charges Texas Housing Authority with Disability Discrimination

Adam Witmer

Regulatory Update

On March 25, 2024, the HUD announced that the it has charged the Grapevine Housing Authority (GHA), Jane Everett (Executive Director of GHA), and Bonnie McHugh (Vice-Chair of the GHA Housing Commission), with discriminating against, and failure to provide a reasonable accommodation for a tenant with a disability. Principal Assistant Deputy Secretary Demetria L. McCain said in a statement that the HUD’s action demonstrates the agency’s steadfast commitment to take appropriate action when housing providers fail to comply with the Fair Housing Act.

Mar 26
Mar 26 Hsu Discusses the Role of Fairness in Compliance Risk Management

Adam Witmer

Regulatory Update

On March 25, 2024, Acting Comptroller of the Currency Michael J. Hsu talked about fairness and effective compliance risk management in his remarks at the Consumer Bankers Association (CBA) LIVE event. The event was held in Washington D.C. with the theme “For the People”.

Mar 25
Mar 25 Agencies Delay Certain CRA Rule Provisions

Adam Witmer

CRA, Regulatory Update

On March 21, 2024, the Federal Reserve, FDIC, and OCC issued a supplemental rulemaking that includes a joint interim final rule which extends the applicability date of certain provisions in their Community Reinvestment Act (CRA) final rule issued in October 2023. The agencies' notice also serves to issue a correction to the preamble to the 2023 CRA Final Rule regarding the OCC’s Unfunded Mandates Reform Act (UMRA) regulatory analysis.

Mar 22

Mar 22 VIDEO: Board Report Requirements for ID Theft Red Flags

Adam Witmer

Regulatory Update, FCRA

In this Compliance Clip (video), Adam enumerates the requirements for reporting identity theft red flags to the board of directors. In addition, Adam describes an alternative for how small financial institutions can report these requirements.

Apr 2
Apr 2 FinCEN Seeks Comments on CIP Rule’s TIN Collection

Apr 1
Apr 1 FDIC Consumer Compliance Supervisory Highlights March 2024 Edition

Apr 1
Apr 1 FDIC Updates its Consumer Compliance Exam Manual

Mar 28
Mar 28 CFPB Announces Availability of 2023 Mortgage Lending HMDA Data

Mar 28
Mar 28 CFPB, Federal and State Agencies Issue Statements on Tech & Enforcement

Mar 28
Mar 28 FATF Highlights Treasury's Anti-Financial Crime Initiatives

Mar 27
Mar 27 HUD Charges Texas Housing Authority with Disability Discrimination

Mar 26
Mar 26 Hsu Discusses the Role of Fairness in Compliance Risk Management

Mar 25
Mar 25 Agencies Delay Certain CRA Rule Provisions

Mar 22 VIDEO: Board Report Requirements for ID Theft Red Flags

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