Payday Loans

On July 7, 2020 the CFPB issued a Final Rule to amend its requirements regarding Payday, Vehicle Title, and Certain High-Cost Installment Loans (12 CFR 1041).  We blogged about the proposed rule and history of the regulation last year. The 2017 Rule had two primary parts – the “Mandatory Underwriting Provisions” (effective 11/19/2020) and the “Payment Provisions” (effective 08/19/2019). The … Read More

June’s Regulatory Recap

June’s Regulatory Recap is now available here.  Let us know if we can help in any way. Please be advised that CSG provides financial services compliance audit and consulting services to our clients.  The services that we provide include certain tasks that may be characterized as “law-related services” under Rule 5.7 of the Rules of Professional Conduct governing lawyers.  Since some of our … Read More

Loans in Areas Having Special Flood Hazards; Interagency Questions and Answers Regarding Flood Insurance

We have reprinted the Q&As from the agencies (OCC, FRB, FDIC, FCA, & NCUA) proposed revamping of the Interagency Questions and Answers Regarding Flood Insurance.  (We did not include the footnotes, but they are available on the linked document.) The questions and answers are broken down by: Determining the Applicability of Flood Insurance Requirements for Certain Loans [Applicability] Exemptions From … Read More

May’s Regulatory Recap

May’s Regulatory Recap is now available here.  Let us know if we can help in any way. Please be advised that CSG provides financial services compliance audit and consulting services to our clients.  The services that we provide include certain tasks that may be characterized as “law-related services” under Rule 5.7 of the Rules of Professional Conduct governing lawyers.  Since … Read More

FAQs on Changes to Regulation D

The Federal Reserve posted additional Q&As relating to their recent rule eliminating the six-per-month convenient withdrawal limitations on savings accounts. Savings Deposits Frequently Asked Questions What is the definition of a “savings deposit” in Regulation D? A “savings deposit” is a deposit or account, such as an account commonly known as a passbook savings account, a statement savings account, or … Read More

The Pandemic and the Compliance Department—Social Distancing Means Changing Risks

With the rampant fraud associated with the pandemic, the institution’s compliance staff may be considered the unsung heroes of the institution.  Along with protecting the institution from steep fines and regulatory violations, the Bank Secrecy Act (BSA) staff protect the institution and customers by identifying and stopping illicit activity. Even with the stay at home orders, these responsibilities continue. With … Read More

Consumer Compliance Outlook

The Federal Reserve issued its first 2020 issue of its Consumer Compliance Outlook. As always, the issue is a good resource for compliance folks. It contains information on regulatory updates, federal court opinions, and commonly cited violations. Included in the violations are violations regarding: spousal signature requirements under Regulation B and evidence of joint intent – especially conflicts between community … Read More

Remittance Transfer Rule

On May 11, the CFPB issued its Final Rule on Regulation E’s remittance transfers requirements, effective July 21, 2020. In advance of the expiration of a statutory exception in July 2020, the Final Rule amendments allow financial institutions to provide estimates of certain fees and the exchange rates related to remittance transfers if they meet certain conditions. The Final Rule … Read More

April’s Regulatory Recap

April’s Regulatory Recap is now available here.  Let us know if we can help in any way. Please be advised that CSG provides financial services compliance audit and consulting services to our clients.  The services that we provide include certain tasks that may be characterized as “law-related services” under Rule 5.7 of the Rules of Professional Conduct governing lawyers.  Since … Read More

Regulation D Convenience Transfer Limitation Dropped

On April 23, 2020, in an Interim Final Rule, the Federal Reserve dropped the convenient transfer limitations from savings deposit accounts of six per month, and now allows unlimited transfers from “savings deposits.” The effective date of the Rule will be 60 days from the date of publication in the Federal Register, but the applicability date was April 23, 2020. … Read More