On October 10, 2019, the CFPB announced that it issued a final rule extending the current temporary threshold of 500 open-end lines of credit for open-end institutional and transactional coverage. For data collection years 2020 and 2021, financial institutions that originated fewer than 500 open-end lines of credit in either of the two preceding calendar years will not need to … Read More
Remittance Transfers
Unless the CFPB extends or removes the expiration of allowing estimates for remittance transfers, financial institutions will need to make sure their disclosures reflect the actual terms of any remittance transfer. Remind me The requirements for remittance transfer disclosures, under Regulation E, include the ability to estimate certain information included on the pre-payment, receipt, or combined disclosures required for remittance … Read More
September’s Regulatory Recap
September’s Regulatory Recap is now available here. If you have any questions, please let us know. Law-Related Services Disclaimer. Please be advised, 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. … Read More
Consumer Compliance
In a speech on September 10, 2019, NCUA Board Member Todd M. Harper gave his opinion regarding consumer financial protection, and the need for improved examinations and enforcement. He stated: Since returning to the NCUA as a Board Member, I have spent some time exploring how the agency conducts consumer financial protection compliance reviews. My interest in this issue was … Read More
August’s Regulatory Recap
It was a quiet month on the legislative front, and our monthly recap is available here. If you have any questions, let us know Law-Related Services Disclaimer. Please be advised, 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 … Read More
July’s Regulatory Recap
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