Nov 11
Nov 11 FTC Takes Action Against Cash Advance App Dave for Deceptive Practices and Hidden Fees

On November 5, 2024, the FTC took action against online cash advance app Dave for allegedly using misleading marketing to deceive consumers about the amount of its cash advances, charging consumers undisclosed fees, and charging so-called “tips” to consumers without their consent. Samuel Levine, Director of the FTC’s Bureau of Consumer Protection, said that Dave lured in consumers living paycheck-to-paycheck with false claims of big-dollar advances, then reached into their pockets to give itself a so-called ‘tip’.

Nov 7
Nov 7 NFIP Issues Final Rule That Provides Insurance Installment Payment Plan

Adam Witmer

Regulatory Update

On November 4, 2024, the Federal Emergency Management Agency (FEMA) issued a final rule revising the National Flood Insurance Program’s (NFIP) regulations to offer NFIP policyholders the option of paying their annual flood insurance premium in monthly installments. The NFIP is a voluntary program in which interested persons can purchase flood insurance for their property if it is located in a community that participates in the NFIP by adopting and enforcing a set of minimum floodplain management requirements to reduce future flood damages.

Nov 5
Nov 5 CFPB Issues Order Against Townstone Financial for Redlining

Adam Witmer

Regulatory Update, Fair Lending

On November 1, 2024, the CFPB filed a proposed order to resolve its case against Townstone Financial for discriminatory lending practices and redlining African American neighborhoods in Chicago. The proposed order would prohibit Townstone from taking any actions that violate the Equal Credit Opportunity Act (ECOA) and require the company to pay a $105,000 penalty to the CFPB’s victims relief fund.

Nov 5
Nov 5 CFPB Fines VyStar Credit Union for Blocking Consumer Access to Accounts

Adam Witmer

Regulatory Update

On October 31, 2024, the CFPB took action against VyStar Credit Union for harming consumers through its botched rollout of a new online banking system. In May 2022, VyStar launched a new online banking platform that was dysfunctional, making it difficult for members to perform basic banking tasks for weeks, with some features unavailable for over six months.

Nov 4
Nov 4 FATF Updates List of Deficient Countries

Adam Witmer

BSA, Regulatory Update

On October 30, 2024, 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 4
Nov 4 FinCEN Extends Filing of BOI Reports to Victims of Recent Natural Disasters

Adam Witmer

Regulatory Update, BSA

On October 29, 2024, FinCEN announced that certain victims of Hurricane Milton, Hurricane Helene, Hurricane Debby, Hurricane Beryl, and Hurricane Francine will receive an additional six months to submit beneficial ownership information reports. The extension includes reporting updates and corrections to prior reports.

Oct 31
Oct 31 Treasury Releases Inaugural National Strategy for Financial Inclusion

Adam Witmer

Regulatory Update

On October 29, 2024, the US Treasury released the National Strategy for Financial Inclusion in the United States. The Strategy identifies objectives and recommendations for policymakers, industry, employers, and community organizations to advance consumer access to safe financial products and services and strengthen financial security.

Oct 30
Oct 30 FHFA Updates Enterprise Policies on Appraisals, Loan Repurchase Alternatives, and Pricing Notifications

Adam Witmer

Regulatory Update

On October 28, 2024, the FHFA announced updates to several Fannie Mae and Freddie Mac policies that are intended to enhance efficiencies and promote cost savings in the single-family mortgage market. FHFA Director Sandra Thompson stated that the actions are intended to better ensure the Enterprises are reliable sources of liquidity for lenders of all sizes and types, which in turn will promote access to sustainable credit for consumers.

Oct 29
Oct 29 NCUA Chairman Harper on Citadel Federal Credit Union’s Redlining Settlement

Adam Witmer

Regulatory Update

On October 10, 2024, NCUA Chairman Todd M. Harper released a statement regarding the U.S. Department of Justice’s settlement with Citadel Federal Credit Union to resolve lending discrimination allegations. Citadel is a $6 billion financial institution in Southeastern Pennsylvania.

Oct 28
Oct 28 CFPB Acts Against Ejudicate for Misleading Student Borrowers

Adam Witmer

Regulatory Update

On October 10, 2024, the CFPB banned private dispute resolution platform Ejudicate from arbitrating disputes about consumer financial products after the company misled student borrowers about its neutrality and initiated sham arbitration proceedings. The CFPB found that Ejucate was actually a debt collection for Prehired, a company permanently shut down in 2023 for illegal lending practices.