We get asked this question frequently, and it comes down to the definition of banks and financial institutions in the Financial Crimes Enforcement Network’s (FinCEN’s) Bank Secrecy Act requirements under Regulation X. Regulation X sets the groundwork for Bank Secrecy Act (BSA) requirements and applies to “financial institutions.” Financial institutions include among others, banks, brokers… Read More »
November’s Regulatory Recap is now available here. It includes new rules from the NCUA, CFPB, FTC and FinCEN, among other happenings during the month. 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 »
October’s Regulatory Recap is now available here. It includes proposed rules on debit card interchange fees, personal financial data rights, and convertible virtual currency mixing, among other happenings during the month. Please be advised that CSG provides financial services compliance audit and consulting services to our clients. The services that we provide include certain tasks… Read More »
The CFPB issued an Advisory Opinion regarding Section 1034(c) of the Dodd Frank Act, which generally prohibits large banks and credit unions from imposing unreasonable obstacles on customers for basic information about their own accounts. Large banks and credit unions under the CFPB’s regime must provide complete and accurate account information when requested by accountholders…. Read More »
September’s Regulatory Recap is now available here. It includes updates to TILA thresholds, proposed regulatory capital rules, and guidance on representment fees, pig butchering, and artificial intelligence on Adverse Action Notices. Please be advised that CSG provides financial services compliance audit and consulting services to our clients. The services that we provide include certain tasks… Read More »
August’s Regulatory Recap is now available here. It includes updates to ADA compliance, a FinCEN alert, 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” under Rule 5.7 of the Rules… Read More »
Beginning Friday, September 1, 2023, the NCUA’s new Cyber Incident Notification Requirements Rule goes into effect. All federally insured credit unions will need to notify the NCUA as soon as possible, and no later than 72 hours, after the credit union reasonably believes it has experienced a reportable cyber incident or received a notification from… Read More »
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… 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… 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… Read More »
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