Proposed Rule – Computer-Security Incident Notification Requirements

The OCC, Federal Reserve, and FDIC have published a two-pronged proposed rule regarding notification of computer-security incidents. The first prong of the proposed rule would require a banking organization to notify its primary federal regulator of any computer-security incident that rises to the level of a notification incident as soon as possible and no later than 36 hours after the … Read More

Updated 314(b) Fact Sheet

FinCEN has updated their Section 314(b) Fact Sheet and has rescinded FIN-2009-G002, which is now incorporated into the Fact Sheet. Under section 314(b) of the Patriot Act financial institutions are permitted to share information with one another regarding individuals they suspect may be involved in terrorist financing or money laundering activities. Those institutions who elect to share information under 314(b) … Read More

The CFPB has issued two final rules to amend the ATR/QM Rule

The CFPB has issued two final rules to amend the ATR/QM Rule. The General QM Final Rule amends the General QM definition. The Seasoned QM Final Rule creates a new category of qualified mortgages. The CFPB states the final rules will “support a smooth and orderly transition away” from the so-called “QM Patch,” which is slated to expire July 1, … Read More

November’s Regulatory Recap

November’s Regulatory Recap is now available here.  Let us know if we can help in any way. CSG will be closed December 24 & 25 for Christmas.  We wish all of you a happy and healthy holiday.     Please be advised that CSG provides financial services compliance audit and consulting services to our clients.  The services that we provide include … Read More

Advisory Opinion Program

The CFPB released its first two Advisory Opinion Letters under its Advisory Opinion Program.  The Advisory Opinion Program provides a mechanism through which the Bureau can more effectively carry out its statutory purposes and objectives by better enabling compliance in the face of regulatory and statutory uncertainty. Parties may submit requests for advisory opinions regarding any issue under the Bureau’s purview … Read More