All in Regulatory Update

On March 27, 2024, the CFPB issued a circular warning remittance transfer providers that false advertising about the cost or speed of sending a remittance transfer can violate federal law. The circular highlights several marketing practices relating to sending international money transfers that may violate the Consumer Financial Protection Act’s (CFPA) prohibition on deceptive acts or practices.

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. 

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.

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.

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.