Jun 9
Jun 9 JUNE CONTEST: Adverse Action Requirements

In case you missed our announcement earlier this week, we are we are holding another contest and will be giving away one free enrollment to Adverse Action Requirements class! Our Adverse Action Requirements program takes a deep dive into everything you and your team need to know about adverse action notices.. In this program, we review the adverse action requirements of both Reg B and FCRA, explain disclosure requirements under the FCRA mandated by the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank Act), and discuss common adverse action violations. To enter the giveaway, just complete a quick entry form at www.compliancecohort.com/entry. To learn more about this program, go to: www.compliancecohort.com/adverse-action-requirements

Jun 5
Jun 5 CFPB Issues Circular Regarding Deceptive Contract Fine Print

Adam Witmer

Regulatory Update, UDAAP

On June 4, 2024, the CFPB issued a circular warning against the use of unlawful or unenforceable terms and conditions in contracts for consumer financial products or services. The CFPB warns they will take action against companies and individuals that deceptively slip coercive contract clauses that censor and restrict individual freedoms and rights into their fine print.

Jun 4
Jun 4 CFPB Creates Registry to Detect Corporate Repeat Offenders

Adam Witmer

Regulatory Update

On June 3, 2024, the CFPB issued a rule to establish a registry to detect and deter corporate offenders that have broken consumer laws and are subject to federal, state, or local government or court orders. The new registry is part of the CFPB’s ongoing focus on holding lawbreaking companies accountable and stopping corporate recidivism.

Jun 3
Jun 3 CFPB Sues Student Loan Servicer PHEAA for Illegal Debt Collection

Adam Witmer

Regulatory Update

On May 31, 2024, the CFPB sued student loan servicer Pennsylvania Higher Education Assistance Agency (PHEAA), which does business as American Education Services (AES), for illegally collecting on student loans that have been discharged in bankruptcy and sending false information about consumers to credit reporting companies. The CFPB seeks to stop PHEAA’s illegal conduct and fine the company for its illegal practices.

Jun 3
Jun 3 Treasury Issues Non-fungible Token Illicit Finance Risk Assessment

Adam Witmer

Regulatory Update, BSA

On May 29, 2024, the Treasury published a 2024 Non-fungible Token (NFT) Illicit Finance Risk Assessment. The risk assessment explores how vulnerabilities associated with NFTs and NFT platforms may be exploited by illicit actors for money laundering, terrorist financing, and proliferation financing.

Jun 3
Jun 3 OCC Issues Alert on Fictitious Regulatory Notifications

Adam Witmer

Regulatory Update

On May 29, 2024, the OCC issued an alert warning against a scam using the name of OCC. According to the OCC, consumers have reported receiving various forms of fictitious correspondence via email, Google Chat, and the U.S. Postal Service related to up-front fee scams involving fictitious inheritance or beneficiary payouts.

Jun 3
Jun 3 CFPB Probes Junk Fees in Mortgage Closing Costs

Adam Witmer

Regulatory Update

On May 30, 2024, the CFPB announced a public inquiry into junk fees that are increasing mortgage closing costs. The Bureau aims to get a clear picture why closing costs are increasing, who is benefiting, and how costs for borrowers and lenders could be lowered.

Jun 3
Jun 3 CFPB on Banks’ Responsibility for Scams

Adam Witmer

Regulatory Update, Regulation E

On May 29, 2024, the CFPB published a blog post discussing a bank’s responsibility when a customer becomes a victim of a scam. The CFPB also issued an amicus brief to argue that the Electronic Fund Transfer Act (EFTA) applies when banks connect the capability to initiate wire transfers to a consumer-facing banking platform.

Jun 3
Jun 3 FHA Requires Cyber Incident Reporting Within 12 Hours

Adam Witmer

Regulatory Update

On May 23, 2024, HUD issued a letter to announce that FHA-approved mortgagees are required to notify HUD when a “Cyber Incident” occurs. Specifically, FHA-approved mortgagees are to report cyber incidents to HUD within 12 hours of detection.

May 31

May 31 VIDEO: Ways to Identify Redlining

Adam Witmer

Fair Lending

In this Compliance Clip (video), Adam explains a number of ways the examiners may identify redlining in an organization. In addition, he breaks down the different types of comparative evidence and overt evidence that could result in redlining. This video provides a great framework for understanding how redlining could appear in your financial institution.