Regulation D Convenience Transfer Limitation Dropped

On April 23, 2020, in an Interim Final Rule, the Federal Reserve dropped the convenient transfer limitations from savings deposit accounts of six per month, and now allows unlimited transfers from “savings deposits.” The effective date of the Rule will be 60 days from the date of publication in the Federal Register, but the applicability date was April 23, 2020. … Read More

March’s Regulatory Recap

March’s Regulatory Recap is now available here.  Let us know if we can help in any way. 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 of Professional Conduct governing lawyers.  Since … Read More

February’s Regulatory Recap

February’s Regulatory Recap is now available here.  Let us know if you have questions, or if we can be of any service. 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 of … Read More

CFPB Supervisory Highlights – Winter 2020… and how CSG can help

In February, the CFPB released its 21st Supervisory Highlights Report. This report covered findings identified in examinations conducted by the CFPB between April 2019 and August 2019. Areas included in the report include mortgage servicing, payday lending (including general Regulation Z requirements), debt collection, and student loan servicing. Mortgage Servicing Highlights Regulation X violations discussed in the report include failing … Read More

January’s Regulatory Recap

January’s Regulatory Recap is now available here. Let us know if you have questions, or if we can be of any service. Law-Related Services Disclaimer. Please be advised, 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 … Read More

2020 NCUA Supervisory Priorities

The NCUA released Letter to Credit Unions 20-CU-01, which highlights their supervisory and examination focus for 2020. Included in the supervisory priorities are: Bank Secrecy Act / Anti-Money Laundering (BSA/AML)  This is not a new priority and is focused on every year. Emphasis for 2020 will be on customer due diligence and beneficial ownership requirements, proper filing of SARs and … Read More

December’s Regulatory Recap

December’s Regulatory Recap is now available here.  If you have questions, please let us know. Law-Related Services Disclaimer. Please be advised, 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 of Professional Conduct governing lawyers. Since … Read More

November’s Regulatory Recap

November’s Regulatory Recap is now available here.  If you have questions, please let us know. Law-Related Services Disclaimer.  Please be advised, 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 of Professional Conduct governing lawyers.  Since … Read More

Alternative Data in Credit Underwriting

The Federal Reserve, CFPB, FDIC, NCUA, and OCC released an Interagency Statement on the Use of Alternative Data in Credit Underwriting.  The statement focuses on the consumer protection implications of the use of alternative data (information not typically found in a credit report) in underwriting, while highlighting potential benefits and risks associated.  One method of alternative data included in the … Read More

CFPB Notice of Proposed Rulemaking to Amend the Remittance Transfer Rule

The CFPB announced its Notice of Proposed Rulemaking (NPRM) regarding remittance transfers requirements under Regulation E.  The CFPB is proposing changes to two areas of the remittance transfer requirements and also asking for comments related to the safe harbor countries list.  The proposed changes include: Increasing the normal course of business safe harbor threshold from 100 to 500 annual remittance … Read More