Regulation E Prohibitions

The CFPB recently issued a Compliance Bulletin reminding providers of the Regulation E prohibitions against requiring prepaid cards as the sole method for distributing government benefits. The Electronic Fund Transfer Act and its implementing Regulation E, state that people cannot be forced to receive government benefits at a specific financial institution as a condition of receiving the benefits. The rule … Read More

January 2022 Regulatory Recap

January’s Regulatory Recap is now available.  It contains regulatory updates, new guidance released, status on Washington State legislative activities, and other actions that may impact your institution. 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 5.7 … Read More

2022 Exam Focus

DCU Bulletin B-22-02 2022 Exam Focus The Washington State Department of Financial Institutions, Division of Credit Unions, released B-22-02 Initiatives and Exam Focus for 2022. The Bulletin describes the DCU’s current initiatives and what examiners will be looking for when conducting annual reviews of state-chartered credit unions during the year. The DCU will use a hybrid approach to exams with … Read More

BSA Civil Money Penalty

In November, FinCEN, along with the OCC, imposed an $8 million BSA Civil Money Penalty against a Texas Bank for willful violations of the Bank Secrecy Act regulations. While the Consent Order leaves a number of questions unanswered, it does provide examples of the violations.  In this post we highlight what we consider to be some of the most relevant … Read More

December’s Regulatory Recap

December’s Regulatory Recap is now available.  It contains regulatory updates, such as the annual Regulation Z threshold adjustments, new guidance released, including the CFPB’s Supervisory Highlights, and other actions taken by the banking supervisors. Our auditing schedule is filling up for 2022.  Contact us now to get on our schedule. Please be advised that CSG provides financial services compliance audit and … Read More

LIBOR Transition Final Rule

On December 7, 2021, the Consumer Financial Protection Bureau (Bureau) issued the 2021 LIBOR Transition Final Rule amending certain provisions in Regulation Z, which implements the Truth in Lending Act (TILA), to address the sunset of LIBOR. Closed-End Credit The LIBOR Transition Final Rule adds an example to the commentary of an index that would be comparable to LIBOR for … Read More

November’s Regulatory Recap

November’s Regulatory Recap for is now available.  It contains regulatory updates, such as the annual Regulation Z threshold adjustments, new guidance released, including the Joint Statement on Supervisory and Enforcement Practices Regarding the Mortgage Servicing Rules in Response to the Continuing COVID-19 Pandemic and CARES Act, and other actions taken by the banking supervisors. Our auditing schedule is filling up … Read More

Computer Security Incidents Notification

On November 18, 2021, the FDIC, OCC, and Federal Reserve approved a final rule requiring institutions to notify their primary federal regulator of any significant computer-security incidents (notification incident) as soon as possible, and no later than 36 hours, after the institution determines that a cyber incident has occurred. Notification incident is a computer-security incident that has materially disrupted or … Read More

Regulation Z Threshold Adjustments

On October 25, the CFPB has issued its annual Regulation Z threshold adjustments.  This final rule adjusts the dollar amounts for Regulation Z (TILA), including the Credit Card Accountability Responsibility and Disclosure Act (CARD Act), the Home Ownership and Equity Protection Act (HOEPA), and the Dodd-Frank Act.  These Regulation Z threshold adjustments are effective January 1, 2022. Minimum interest charges … Read More

Small Business Lending Data Collection Under the Equal Credit Opportunity Act

On September 1, 2021, the CFPB published proposed rulemaking on small business lending data collection. The proposal would require covered financial institutions to annually collect and report to the Bureau data on credit applications for small businesses, including those that are owned by women or minorities. The proposed rule is 918 pages long. The CFPB also provides a table of … Read More