June 2022’s Regulatory Recap is now available here. Guidance from the FinCEN and CFPB and the Latest Consumer Financial Protection Circulars from the Bureau are included in June 2022’s Regulatory Recap. We are now half-way through the year. We still have a limited number of audit slots open for the remainder of the year. If you don’t see what you are … Read More
Serving Non-Members
The Washington State Legislature passed HB 1165, which made several changes to the Washington State Credit Union Act. The changes are effective June 9, 2022. One of those changes allows credit unions to serve certain non-members in a limited capacity. Washington State credit unions can “cash checks, money orders, and other payment instruments for members and persons who are eligible … Read More
May 2022’s Regulatory Recap
May 2022’s Regulatory Recap is now available here. Updates to the Flood Insurance Q&As, new Supervisory Highlights, FDIC Insurance Advertising requirements and prohibitions, and others are included in May 2022’s Regulatory Recap. As we are heading into Summer, we still have a limited number of audit slots open for the remainder of the year. If you don’t see what you … Read More
Thank You!
Thank you! Next month marks the 10th anniversary of my joining Compliance Services Group, and I want to take a moment and thank you all for trusting us for your auditing and consulting needs. When we started in June of 2012, Northwest Compliance Group was focused on helping a limited number of Washington state institutions navigate the regulatory landscape. The … Read More
April’s Regulatory Recap
April’s Regulatory Recap is now available here. It’s a short one this month, and the only thought that is running through my head is the calm before the storm. Are you keeping up with everything that you should be? Our Weekly Rewinds, which generally come out on Tuesday morning, contains regulatory and supervisory actions for the previous week. Previous issues are … Read More
Supervisory Highlights & Overdraft Programs
The FDIC published the latest version of Consumer Compliance Supervisory Highlights which provides an overview of compliance activities and issues identified through FDIC examinations. These Supervisory Highlights should be a required read for all compliance or risk-management staff in any financial organization. With the increased focus on junk fees and overdraft programs, one area in this issue that caught our … Read More
March 2022 Regulatory Recap
March’s Regulatory Recap is now available. It contains important important news and updates from the regulators. During March, the CFPB had quite a bit to say about fairness, discrimination, and junk fees. Take a look, and let us know if you have any questions. The FDIC published the latest issue of it Consumer Compliance Supervisory Highlights. This is always a … Read More
ECOA
In February, the NCUA issued Letter to Credit Unions 22-CU-04, Equal Credit Opportunity Act Nondiscrimination Requirements. With the CFPB’s increased focus on unfair discrimination, a deeper dive into the Letter is appropriate. The Letter summarizes general nondiscrimination requirements under the Equal Credit Opportunity Act (ECOA) relating to marital status, ages, income consideration, redlining, and indirect lending. The ECOA prohibits discrimination … Read More
Bank Secrecy Act Violations Can Be Costly
Recently, FinCEN and the OCC assessed a $140,000,000 civil money penalty against USAA Federal Savings Bank for alleged ongoing compliance deficiencies in its Bank Secrecy Act program. There were a number of triggers that lead up to the assessment, with many relating to the compliance department not keeping up with USAA’s rapid growth. Institutions should review the Assessment, and compare … Read More
What Is Unfair?
Updated UDAAP Focus The CFPB has increased its focus on unfair discrimination in the financial markets. It has published an updated exam manual for evaluating UDAAPs for both deposit and loan products. In examinations, the CFPB will be looking at financial institutions decision making in advertising, pricing, and other areas to ensure that institutions are appropriately testing for and eliminating … Read More