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.

Agencies Issue Final Rule on Automated Valuation Models

Adam Witmer
Regulatory Update, Fair Lending

On July 17, 2024, the CFPB, FDIC, FHFA, FRB, NCUA, and OCC jointly issued a final rule, pursuant to the Dodd-Frank Wall Street Reform and Consumer Protection Act, designed to help ensure the credibility and integrity of models used in valuations for certain mortgages secured by a consumer's principal dwelling. In particular, the rule will implement quality control standards for automated valuation models (AVMs) used by mortgage originators and secondary market issuers in valuing those homes.

FinCEN, OFAC, and FBI Issues Joint Notice on Timeshare Fraud Associated with Mexico-Based Organizations

Adam Witmer
Regulatory Update, BSA

On July 16, 2024, FinCEN, OFAC, and the FBI issued a joint Notice to financial institutions urging them to be vigilant in detecting, identifying, and reporting timeshare fraud perpetrated by Mexico-based transnational criminal organizations. The Notice provides methodologies, typologies, and red flag indicators to help financial institutions identify potential timeshare fraud in their transactions.

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