2021 Washington Legislative Session

The Washington State legislative session opens today, Monday January 11, 2021.  The Legislature begins each legislative session annually on the second Monday in January. In odd-numbered years, such as when the state budget is debated upon, the State Legislature meets for 105 days, and in even-numbered years, it meets for 60 days. The cut-off dates for this session are: Monday, … Read More

Federal Credit Unions and Community Charter Conversions and Expansions

In Letter to Federal Credit Unions 21-FCU-01, the NCUA provides updated guidance and templates to assist federal credit unions seeking to convert to a community field of membership or expand their existing community field of membership. This letter replaces the guidance previously provided in NCUA Letter to Federal Credit Unions 11-FCU-03, Community Charter Conversions and Expansions. Since 11-FCU-03 was issued, the NCUA … Read More

Federal Credit Unions and Underserved Area Expansions

The NCUA issued Letter to Federal Credit Unions 21-FCU-03 stating that “any federal credit union with a multiple common bond field of membership may include in its field of membership, without regard to location, underserved communities as defined by the Federal Credit Union Act. To promote greater financial inclusion and strengthen communities, the NCUA encourages such credit unions to expand … Read More

December’s Regulatory Recap

December’s Regulatory Recap is now available at https://complianceservicesgroup.com/wp-content/uploads/2021/01/REGULATORY-RECAP-December-2020.pdf. Let us know if you have any questions or if we can help in some 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 … Read More

Proposed Rule – Computer-Security Incident Notification Requirements

The OCC, Federal Reserve, and FDIC have published a two-pronged proposed rule regarding notification of computer-security incidents. The first prong of the proposed rule would require a banking organization to notify its primary federal regulator of any computer-security incident that rises to the level of a notification incident as soon as possible and no later than 36 hours after the … Read More

Updated 314(b) Fact Sheet

FinCEN has updated their Section 314(b) Fact Sheet and has rescinded FIN-2009-G002, which is now incorporated into the Fact Sheet. Under section 314(b) of the Patriot Act financial institutions are permitted to share information with one another regarding individuals they suspect may be involved in terrorist financing or money laundering activities. Those institutions who elect to share information under 314(b) … Read More

The CFPB has issued two final rules to amend the ATR/QM Rule

The CFPB has issued two final rules to amend the ATR/QM Rule. The General QM Final Rule amends the General QM definition. The Seasoned QM Final Rule creates a new category of qualified mortgages. The CFPB states the final rules will “support a smooth and orderly transition away” from the so-called “QM Patch,” which is slated to expire July 1, … Read More

November’s Regulatory Recap

November’s Regulatory Recap is now available here.  Let us know if we can help in any way. CSG will be closed December 24 & 25 for Christmas.  We wish all of you a happy and healthy holiday.     Please be advised that CSG provides financial services compliance audit and consulting services to our clients.  The services that we provide include … Read More

Advisory Opinion Program

The CFPB released its first two Advisory Opinion Letters under its Advisory Opinion Program.  The Advisory Opinion Program provides a mechanism through which the Bureau can more effectively carry out its statutory purposes and objectives by better enabling compliance in the face of regulatory and statutory uncertainty. Parties may submit requests for advisory opinions regarding any issue under the Bureau’s purview … Read More

Changes to Privacy Notices on the Horizon?

The Government Accountability Office (GAO) published a report which said that the current privacy model form gives consumers only a limited understanding of financial institutions’ information sharing.  The GAO recommended that the CFPB update the form and consider adding more information about third party sharing. The increasing amounts of and changing ways in which industry collects and shares consumer personal … Read More