July’s Regulatory Recap is now available at https://complianceservicesgroup.com/wp-content/uploads/2019/08/REGULATORY-RECAP-July-2019.pdf. Also, as a reminder, the private flood insurance requirements went into effect on July 1, 2019. We have received a number of questions on the requirements, and have blogged about it here. If you have questions on it, or any other regulatory issues, let us know. Law-Related Services Disclaimer. Please be advised, … Read More
June’s Regulatory Recap
June’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
Consumer Compliance Supervisory Highlights
Earlier this month, the FDIC released the inaugural issue of Consumer Compliance Supervisory Highlights. The Highlights are intended to provide the public and supervised institutions with information and observations related to the FDIC’s supervisory activities. It also includes a high-level overview of identified consumer compliance issues. This is a great read for anyone in a compliance-related position, not just those … Read More
Delayed Final Payday Rule
On June 6, 2019, the CFPB issued the latest final Payday Lending Rule formally delaying the compliance dates for the mandatory underwriting provisions and making technical corrections to the payment provisions of the original Rule. The compliance dates are set out in a new section, §1041.15, of the Rule. The Executive Summary notes that the Bureau “continues to consider comments … Read More
May’s Regulatory Recap
May’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
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 contactus@complianceservicesgroup.com 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
March’s Regulatory Recap
March’s Regulatory Recap is now available here. It includes legislative updates regarding new proposed and final rules for March 2019, as well as Washington and Oregon state updates. So, grab a cup of coffee, tell the boss you will be busy for the next 10 minutes, and enjoy… Let us know if you have any questions. Law-Related Services Disclaimer. Please … Read More