The Blog

The Association of Credit Union Internal Auditors, Inc., recently awarded Justin Hosie and our own Cliff Cook the Pat Richey 2023 Article of the Year for their informative and entertaining article on Regulation Z’s top 10 material violations. TILA and Regulation Z:  Top 10 Material Violations By: Justin Hosie[1] and Cliff Cook[2] June 5, 2022 If you saw the title … Read More

July 2023’s Regulatory Recap is now available here. It includes guidance on reconsiderations of value of residential real estate valuations, NCUA Federal Credit Union Bylaw updates, and supervisory highlights. 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” … Read More

The CFPB, along with the State of Maine, filed an amicus brief with the Supreme Court of Maine, dated July 12, 2023, arguing that determining whether a loan is covered by TILA requires assessing all material facts and circumstances relevant to determine the borrower’s primary purpose of entering into the transaction. In short, this case involves borrowers who took out … Read More

“Junk Fees” seems to be the catchphrase of the year. In his State of the Union address on February 7, 2023, President Biden urged Congress to enact legislation eliminating junk fees. As a result, Senators Blumenthal (CT) and Whitehouse (RI) have introduced the Junk Free Prevention Act. The introduced legislation specifically targets excessive online ticket fees, airline family seating fees, … Read More

June 2023’s Regulatory Recap is now available here. It includes guidance on third-party risk management, commercial real estate loan accommodations and workouts, small business lending FAQs, and 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

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 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

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

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 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