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


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

February 2022’s Regulatory Recap

February’s Regulatory Recap is now available.  February did not have many new or proposed regulations issued, but there was a lot of guidance documents issued from the CFPB and other regulatory agencies included in the Regulatory Recap. Get On Our Audit Schedule Now We are quickly filling up our audit schedule for 2022. While we are continuing to provide remote … Read More

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