Permissible Purpose & No Other Purpose

Last week, I received a letter from my credit union stating: “Because of your excellent credit record we’re increasing the limit on your credit card.” This got me thinking about whether the institution had a permissible purpose to review my credit. Section 604 of the Fair Credit Reporting Act requires that credit bureaus (credit reporting agencies, or CRAs) must have … Read More

Updates to Washington Trust Institutions Act – Effective July 28, 2019

CSG’s Senior Compliance Consultant, Ali Higgs, sent the following notice to our trust company clients earlier this week. Provided below is a copy for your convenience. If you are a trust company looking for consulting or auditing services, please message us at or call us at (360) 943-7137. Dear Xxxx: As you may be aware, the Washington State Department … Read More

A Framework for OFAC Compliance

On May 2, the Office of Foreign Assets Control published A Framework for OFAC Compliance Commitments. The Framework includes an expected Sanctions Compliance Program (SCP) that institutions should consider when developing their own risk-based OFAC compliance program. There is no “one size fits all” SCP for institutions, and each institution should establish a risk-based program based on the institution’s size … Read More

April’s Regulatory Recap

April’s Regulatory Recap is now available.  It includes the legislative update for Washington and Oregon, along with a recap of proposed and final rules from D.C.  Let us know if you have any questions, or if we can help in any way. Law-Related Services Disclaimer.  Please be advised, CSG provides financial services compliance audit and consulting services to our clients.  … Read More