In February, the NCUA issued Letter to Credit Unions 22-CU-04, Equal Credit Opportunity Act Nondiscrimination Requirements. With the CFPB’s increased focus on unfair discrimination, a deeper dive into the Letter is appropriate. The Letter summarizes general nondiscrimination requirements under the Equal Credit Opportunity Act (ECOA) relating to marital status, ages, income consideration, redlining, and indirect lending. The ECOA prohibits discrimination … Read More

Bank Secrecy Act Violations Can Be Costly

Recently, FinCEN and the OCC assessed a $140,000,000 civil money penalty against USAA Federal Savings Bank for alleged ongoing compliance deficiencies in its Bank Secrecy Act program.  There were a number of triggers that lead up to the assessment, with many relating to the compliance department not keeping up with USAA’s rapid growth.  Institutions should review the Assessment, and compare … Read More

What Is Unfair?

Updated UDAAP Focus The CFPB has increased its focus on unfair discrimination in the financial markets.  It has published an updated exam manual for evaluating UDAAPs for both deposit and loan products.  In examinations, the CFPB will be looking at financial institutions decision making in advertising, pricing, and other areas to ensure that institutions are appropriately testing for and eliminating … Read More

February 2022’s Regulatory Recap

February’s Regulatory Recap is now available.  February did not have many new or proposed regulations issued, but there was a lot of guidance documents issued from the CFPB and other regulatory agencies included in the Regulatory Recap. Get On Our Audit Schedule Now We are quickly filling up our audit schedule for 2022. While we are continuing to provide remote … Read More