May 2023’s Regulatory Recap is now available here. It includes guidance on reopening previously closed deposit accounts, small business lending data collection, and others. John Bley and Sarah Young will be attending the ACUIA’s 33rd annual conference in San Fransico, June 13 through the 16th. On Thursday, the 15th, John will be discussing third party risks during one of the … Read More
April 2023’s Regulatory Recap
April 2023’s Regulatory Recap is now available here. It includes guidance on discrimination and bias in automated systems, LIBOR transition, time-barred debt, and business email compromises, among others. 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 … Read More
Supervisory Guidance on Charging Overdraft Fees for Authorize Positive, Settle Negative Transactions
The FDIC issued Supervisory Guidance (FIL-19-2023) to ensure that institutions are aware of the consumer compliance risks associated with assessing overdraft fees on a transaction that was authorized against a positive balance but settled against a negative balance (APSN). The guidance expands on an FDIC 2019 Supervisory Highlights article titled “Overdraft Programs: Debit Card Holds and Transaction Processing” by discussing … Read More
Bulletin B-23-03 (Wire Fraud Alert and Recommendations)
The Washington State Department of Financial Institutions, Division of Credit Unions has published Bulletin B-23-03 (Wire Fraud Alert and Recommendations). We have reprinted it below for your convenience – Wire Fraud Alert and Recommendations Based on reports and incidents from consumers in Washington State, the Division would like to emphasize the importance for Credit Unions to exercise a heightened … Read More
March 2023’s Regulatory Recap
March 2023’s Regulatory Recap is now available here. This month’s Recap includes the new Small Business Lending Reporting rule from the CFPB, analytics on buy now, pay later borrower profiles, junk fees, and mail-theft related check fraud. Please be advised that CSG provides financial services compliance audit and consulting services to our clients. The services that we provide include certain … Read More
February 2023’s Regulatory Recap
February 2023’s Regulatory Recap is now available here. The Regulatory Recap includes FinCEN guidance on Mail Theft-Related Check Fraud, a proposed rule from the U.S. Treasury on requiring institutions to use the Treasury Check Verification System to verify that Treasury checks are both authentic and valid before negotiating, and the final NCUA Rule on Reportable Cycber Incidents, among other items. … Read More
Cyber Incident Notification Requirements for Federally Insured Credit Unions
The NCUA Board unanimously approved a final rule that requires a federally insured credit union to notify the NCUA as soon as possible, and within 72 hours, after it reasonably believes that a reportable cyber incident has occurred. Under the final rule, federally insured credit unions are required to report a cyber incident that leads to a substantial loss of … Read More
January 2023 Regulatory Recap
The January 2023 Regulatory Recap is now available here. The Regulatory Recap includes FinCEN Guidance on human smuggling and sanctioned Russian elites, proposed rules from the CFPB, and supervisory priorities, along with agency guidance. Our 2023 audit calendar is open and filling up fast! Whether you are looking for a BSA exam, loan compliance review, help making sure your LAR … Read More
December’s Regulatory Recap
December’s Regulatory Recap is now available here. The Regulatory Recap contains new inflation adjustments from the CFPB, proposed rules from the FDIC & NCUA, along with agency guidance. Welcome to 2023 – the Year of the Question Mark. It seems that everyone is guessing what will happen – interest rates continue to go up, slow down, or decrease, the CFPB’s … Read More
November’s Regulatory Recap
November’s Regulatory Recap is now available here. The Regulatory Recap contains new rules from the CFPB, HUD, and FTC, along with new guidance from the CFPB regarding deposit related fees. As we are entering December, our auditors are busier than Santa’s elves working on wrapping up projects for our clients. This always seems to be our busy season, with institutions … Read More