Ask the CFPB

The CFPB has created a new online form for asking informal staff guidance on questions about CFPB regulations.  From the CFPB’s page: The Bureau’s Office of Regulations offers financial institutions, service providers, and others informal staff guidance on specific questions about the Bureau’s regulations. The Bureau also makes available on its website extensive written implementation and guidance materials, which answer … Read More

Adequate Controls in Place?

The FDIC shared a Department of Justice report on a credit union employee, and her on-line boyfriend, Phillip Cook, fraudulently obtaining more than 30 lines of credit worth over $2.6 million.  The employee, Indira Mohabir, was a business loan processor at Western Federal Credit Union, and opened lines of credit without necessary oversight and approval from the credit union.  “In exchange … Read More

OCC Bulletin 2017-28

Risk Management Guidance for Higher-Loan-to-Value Lending Programs in Communities Targeted for Revitalization The OCC issued Bulletin 2017-28 regarding circumstances under which banks may establish a program to originate certain higher-LTV loans, and OCC’s supervisory considerations regarding such programs.  These programs may be eligible for Community Reinvestment Act credit. The guidance provides information about the required policies and procedures under such … Read More

Operation Chokepoint is Officially Choked Out

In an August 16, 2017, letter to the Judiciary Committee, the Department of Justice stated that “All of the Department’s bank investigations conducted as part of Operation Chokepoint are not over, the initiative is no longer in effect, and it will not be undertaken again.” Operation Chokepoint was the brainchild of the Department of Justice to curtail legal but disfavored … Read More

HMDA Examiner Testing Guidelines

The FFIEC released its HMDA Examiner Transaction Testing Guidelines for institutions that report HMDA data.  The Guidelines will apply to examination of HMDA data collected beginning in 2018 and reported beginning in 2019. From the CFPB: The Guidelines will help ensure accurate data and address reporting burden concerns When examining financial institutions, federal supervisory agencies with HMDA supervisory authority may … Read More

GTO & FIN-2017-A003

On August 22, 2017, FinCEN issued Geographic Targeting Orders directed at title insurance companies and properties in areas of Texas, Florida, New York, California and Hawaii. While financial institutions have no requirements related to this GTO, FinCEN simultaneously issued FIN-2017-A003, Advisory to Financial Institutions and Real Estate Firms and Professionals. FinCEN’s press release explains that it published the Advisory “to … Read More

Oregon Data Match Requirements

Oregon Financial Institutions will need to abide by the new requirements of the data match system by July 1, 2018.  The data match system is a mandatory scrub of accounts against a state provided list of names and social security numbers of delinquent debtors (having a Department of Revenue warrant). The State will reimburse financial institutions for participating in the … Read More

Press Release

OLYMPIA, WASHINGTON – [August 10, 2017] – John Bley, President and CEO of Compliance Services Group, LLC fka NW Compliance Group, LLC (NWCG) is pleased to announce we are joining with nationally known compliance expert Cliff Cook and his group of experienced consultants at Compliance Services, Inc. (CSI). Effective August 1, 2017, the combined company is operating under the name … Read More

July Recap

July’s Legislative Recap has been uploaded here.  Let us know if you have questions.  

Pay-by-Phone Fees Could Lead to UDAAP Violations

On July 27, 2017 the CFPB issued Compliance Bulletin 2017-01:  Phone Pay Fees, reminding companies that misleading consumers about fees associated with payments over the telephone may be deemed as UDAAP violations. The Bulletin states, that depending on the facts and circumstances, the following may constitute UDAAP violations: Failing to disclose the prices of all available phone pay fees when … Read More