The Government Accountability Office (GAO) published a report which said that the current privacy model form gives consumers only a limited understanding of financial institutions’ information sharing. The GAO recommended that the CFPB update the form and consider adding more information about third party sharing. The increasing amounts of and changing ways in which industry… Read More »
The Office of the Comptroller of the Currency (OCC) has issued a proposed rule to ensure that banks and federal savings associations provide fair access to financial services and not make board-based decisions that affect classes or categories of customers. This proposed rule would prohibit covered national banks and federal savings associations—generally, those with $100… Read More »
During its November 19th board meeting the NCUA issued a proposed rule that would allow credit unions to include unpaid interest in loan workouts and modifications. The proposal includes commercial and business loans. The proposed rule would amend Appendix B to Part 741 – Loan Workouts, Nonaccrual Policy, and Regulatory Reporting of Troubled Debt Restructured… Read More »
The Federal Reserve, FDIC, FinCEN, NCUA and OCC issued a fact sheet clarifying that compliance efforts to meet Bank Secrecy Act due diligence requirements for customers that are charities and other nonprofit organizations should be based on the money laundering risks posed by the customer relationship. The fact sheet highlights the importance of legitimate charities… Read More »
The Financial Stability Board (FSB) published a discussion paper titled Regulatory and Supervisory Issues Relating to Outsourcing and Third-Party Relationships. The paper builds on the FSB’s 2019 report Third-Party Dependencies in Cloud Services and a survey conducted during the first quarter of 2020 on the existing regulatory and supervisory landscape related to outsourcing and third-party… Read More »
On October 30, 2020, the Consumer Financial Protection Bureau (Bureau) issued a final rule to restate and clarify prohibitions on harassment and abuse, false or misleading representations, and unfair practices by debt collectors when collecting consumer debt. The rule focuses on debt collection communications and gives consumers more control over how often and through what means… Read More »
The CFPB’s November Quarterly Consumer Credit Trends report examines how often lenders report, or furnish, information on borrowers’ actual payment to nationwide consumer reporting agencies. The report finds that actual payment furnishing for installment loan products including mortgages, auto, and student loans has steadily increased between 2012 and 2020. Over the same period, actual payment… Read More »
The Office of the Comptroller of the Currency (OCC) published its Fall 2020 Semiannual Risk Perspective. Naturally, COVID-19 is a large factor on the risk environment for financial institutions. These risks include credit risks and consumers’ ability to service debts, financial performance in a long-term low-rate environment, cybersecurity risks from altered work environments, and compliance… Read More »
On October 23, 2020 the Financial Action Task Force (FATF) updated its list of jurisdictions with strategic deficiencies in their regimes to counter money laundering, terrorist financing, and proliferation financing. The change may affect financial institutions’ obligations and risk-based approaches with respect to relevant jurisdictions. In Summary: Identified high-risk jurisdictions remain the same as the… Read More »
The Financial Crimes Enforcement Network (FinCEN) announced the renewal of its Geographic Targeting Orders (GTOs) that require U.S. title insurance companies to identify the natural persons behind shell companies used in all-cash purchases of residential real estate. These renewed GTOs are identical to the May 2020 GTOs. The purchase amount threshold remains $300,000 for each covered… Read More »
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