All in Regulatory Update

Agencies Seek Comment on Interagency Effort to Reduce Regulatory Burden

Adam Witmer
Regulatory Update

On July 25, 2024, the FDIC, the FRB, and the OCC issued a notice requesting comment to reduce regulatory burden. The Economic Growth and Regulatory Paperwork Reduction Act of 1996 requires the Federal Financial Institutions Examination Council (FFIEC) and federal bank regulatory agencies to review their regulations every 10 years to identify outdated or otherwise unnecessary regulatory requirements for their supervised institutions.

Agencies Request Info on Third-Party Arrangements

Adam Witmer
Regulatory Update

On July 25, 2024, the FDIC, the FRB and the OCC requested additional information on a broad range of bank-fintech arrangements, including with respect to deposit, payments, and lending products and services. Additionally, the agencies issued a statement reminding banks of potential risks associated with third-party arrangements to deliver bank deposit products and services.

CFPB Warns Against Threatening Whistleblowers

Adam Witmer
Regulatory Update

On July 24, 2024, the CFPB issued a circular to law enforcement agencies and regulators explaining how companies may be breaking the law by requiring employees to sign broad nondisclosure agreements that could deter whistleblowing. The circular explains how imposing sweeping nondisclosure agreements that do not clearly permit communication with law enforcement may intimidate employees from disclosing misconduct or cooperating with investigations.

Treasury Issues New Reporting Requirements Under the REPO for Ukrainians

Adam Witmer
Regulatory Update

On July 23, 2024, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) has issued a new reporting requirement for financial institutions holding Russian sovereign asset as part of implementing the historic Rebuilding Economic Prosperity and Opportunity for Ukrainians Act (the “REPO for Ukrainians Act”). The new reporting requirement mandates all financial institutions at which Russian sovereign assets are located, and that know or should know of such assets, to provide notice of such assets to OFAC no later than August 2, 2024 or within 10 days of the detection of such assets, and can do so via OFAC’s new form.

FRB Fines Green Dot for Numerous Violations

Adam Witmer
Regulatory Update, BSA, UDAAP

On July 19, 2024, the Federal Reserve Board took action to address consumer compliance breakdowns by Green Dot, fining the firm $44 million for numerous unfair and deceptive practices and a deficient consumer compliance risk management program. According to the Federal Reserve Board’s press release, Green Dot violated consumer law in its marketing, selling, and servicing of prepaid debit card products, and its offering of tax return preparation payment services. 

Agencies Request Comment on AML/CFT Proposed Rule

Adam Witmer
BSA, Regulatory Update

On July 19, 2024, the OCC, the Federal Reserve Board, the FDIC, and the NCUA issued a notice of proposed rulemaking to to update their requirements for supervised institutions to establish, implement, and maintain effective, risk-based, and reasonably designed anti-money laundering and countering the financing of terrorism (AML/CFT) programs. According to the FDIC’s press release, the amendments are intended to align with changes concurrently proposed by the U.S. Department of the Treasury’s FinCEN.

Agencies Issue Interagency Guidance on ROVs for Residential Real Estate Valuations

Adam Witmer
Regulatory Update

On July 18, 2024, the CFPB, FDIC, FRB, NCUA, and OCC issued final guidance addressing reconsiderations of value (ROVs) for residential real estate transactions. The final guidance also provides examples of policies and procedures that a financial institution may choose to implement to help identify, address, and mitigate the risk of discrimination impacting residential real estate valuations.

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