November’s Regulatory Recap is now available here. If you have 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. Since … Read More
Alternative Data in Credit Underwriting
The Federal Reserve, CFPB, FDIC, NCUA, and OCC released an Interagency Statement on the Use of Alternative Data in Credit Underwriting. The statement focuses on the consumer protection implications of the use of alternative data (information not typically found in a credit report) in underwriting, while highlighting potential benefits and risks associated. One method of alternative data included in the … Read More
CFPB Notice of Proposed Rulemaking to Amend the Remittance Transfer Rule
The CFPB announced its Notice of Proposed Rulemaking (NPRM) regarding remittance transfers requirements under Regulation E. The CFPB is proposing changes to two areas of the remittance transfer requirements and also asking for comments related to the safe harbor countries list. The proposed changes include: Increasing the normal course of business safe harbor threshold from 100 to 500 annual remittance … Read More
October’s Regulatory Recap
October’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
CFPB Extends the 500 open-end lines of credit threshold to January 1, 2022
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