On April 7, 2022, the FDIC published a letter to notify all FDIC-supervised institutions that intend to engage in, or that are currently engaged in, any activities involving or related to crypto assets or “digital assets” should notify the FDIC. FDIC-supervised institutions are requested to provide information described in the letter and the FDIC will review the information and provide relevant supervisory feedback.

On April 8, 2022, the CFPB issued a proposed rule amending Regulation V that would implement amendments to the Fair Credit Reporting Act that assist consumers who are victims of trafficking. The proposed rule would establish a procedure for a victim of trafficking to submit documentation to consumer reporting agencies, including information identifying any adverse item of information about the consumer that resulted from certain types of human trafficking. In addition, the proposed rule would prohibit the consumer reporting agencies from furnishing a consumer report containing the adverse item(s) of information.

VIDEO: Flood Zone Discrepancy with Appraisal & Determination

In this Compliance Clip, Adam gives valuable insights on what to do when there is a discrepancy between appraisal and flood determination forms. In particular, this video uses the example of a commercial building in multiple structures wherein the flood determination says that the structures are not in a high risk flood zone while based on the appraisal, one of the structures is in a high-risk flood zone. A transcript of this video is now available.

On April 6, 2022, the CFB published a report which reveals few payday loan borrowers are benefiting from no-cost extended payment plans, which are required to be offered to borrowers in the majority of states that do not prohibit payday lending. According to the CFPB, borrowers continue to pay for costly loan rollovers instead of using the payment plans. While no-cost extended payment plans are meant to help borrowers exit the cycle of rollovers and fees, the payday business model continues to depend on high rollover rates and fees.

On April 5, 2022, the OFAC sanctioned the world’s largest and most prominent darknet market, Hydra Market (Hydra), in a coordinated international effort to disrupt proliferation of malicious cybercrime services, dangerous drugs, and other illegal offerings available through the Russia-based site. The operation was a collaborative initiative joined by the DOJ, FBI, DEA, IRS Criminal Investigation, and ICE.

On 3/29/2022, the FDIC announced that the Federal Financial Institutions Examination Council (FFIEC) had issued the 2022 edition of A Guide to HMDA Reporting: Getting It Right! for Home Mortgage Disclosure Act (HMDA)-related data collected in 2022 and reported in 2023. This longstanding compliance resource has regularly been used by financial institutions as a “go-to” HMDA resource as it can help financial institutions better understand HMDA requirements, including the data collection and reporting provisions.

On March 31, 2022, the FDIC issued the March 2022 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 2021 through the FDIC’s supervision of state non-member banks and thrifts.

On May 1, 2022, banks must comply with a new rule to notify their regulators of certain cyber incidents. If your institution isn’t yet ready for this rule, our training program - Cyber Incident Notification Rule 2022 - is designed to help your bank quickly and easily understand the new interagency cyber-incident notification final rule. Our team has spent hours sifting through the new rule to determine what bankers need to know. While our accompanying manual is 38 pages in length - due to us including beneficial background information on the rule - our video presentation breaks down the new rule in an easy to understand format, using layman’s terms. You can learn more about our training program at: www.compliancecohort.com/cyber-incident-notification-rule-2022.

VIDEO: Provisions of RESPA Section 8

In this Compliance Clip, Adam gives a quick overview of the four provisions of Section 8 of the Real Estate Settlement Procedures Act (RESPA). To better explain how the provisions are incorporated in the regulations, Adam gives a quick visual of the actual law and Regulation X, where the RESPA Section 8 provisions are embedded.