FDIC's 2024 Risk Review

Adam Witmer
Regulatory Update

On May 22, 2024,  the FDIC  published its 2024 Risk Review which summarizes conditions in the U.S. economy, financial markets, and banking industry. According to the FDIC, economic conditions remained strong in 2023, and financial market conditions improved toward the end of the year. In addition, the banking industry demonstrated resilience after a period of stress in early 2023 as full-year net income remained high, overall asset quality metrics were favorable, and liquidity stabilized.

FinCEN’s New Initiative to Fight Fentanyl Trafficking

Adam Witmer
Regulatory Update, BSA

On May 20, 2024, FinCEN announced a new initiative to combat the illicit trafficking of fentanyl into the United States as part of the Treasury Department’s Counter-Fentanyl Strike Force and in partnership with IRS Criminal Investigation (CI). The new FinCEN Exchange series, titled “Promoting Regional Outreach to Educate Communities on the Threat of Fentanyl” (or PROTECT), will be held through the remainder of 2024 in U.S. cities that are highly impacted by the opioid epidemic. 

CFPB Takes Action Against Western Benefits for Illegal Practices

Adam Witmer
Regulatory Update

On May 20, 2024, the CFPB took action against Western Benefits Group for charging illegal advance fees for student loan debt relief services and misrepresenting to consumers that advance fees would go toward paying down their loans. In addition, the company is alleged to have misrepresented that it was affiliated with and endorsed by the Department of Education, and that it would help consumers consolidate student loans, lower consumers’ monthly student loan payments, or obtain loan cancellation.

FDIC’s Settlement with Bank of England for Violations of Consumer Protection Laws

Adam Witmer
Regulatory Update, RESPA, HMDA, FCRA

On May 17, 2024, the FDIC announced that a settlement was reached with Bank of England, England, Arkansas, for violations of Section 5 of the Federal Trade Commission Act, the Real Estate Settlement Procedures Act (RESPA), the Fair Credit Reporting Act (FCRA), and the Home Mortgage Disclosure Act (HMDA). Nine former employees of the Bank of England have also stipulated to individual enforcement actions.

Hsu Testifies Before Congress and Highlights OCC’s Priorities

Adam Witmer
Regulatory Update

On May 15, 2024, Acting Comptroller Michael J. Hsu today testified on the OCC’s priorities before the Committee on Financial Services of the U.S. House of Representatives and provided an update regarding the Agency’s initiatives. In his testimony, Mr. Hsu discussed the OCC’s work to guard against complacency, adapt to digitalization, manage climate-related financial risk, and promote fairness in banking. 

Revised HMDA Getting It Right Guide for 2024

Adam Witmer
Regulatory Update, HMDA

On May 14, 2024, the FFIEC issued the 2024 edition of A Guide to HMDA Reporting: Getting It Right! for Home Mortgage Disclosure Act (HMDA)-related data collected in 2024 and reported in 2025. 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.

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