The Blog

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 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

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

FinCEN has updated their Section 314(b) Fact Sheet and has rescinded FIN-2009-G002, which is now incorporated into the Fact Sheet.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 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 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

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

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

During its November 19th board meeting the NCUA issued a proposed rule that would allow credit unions to include unpaid interest in loan workouts and modifications.  The proposal includes commercial and business loans.  The proposed rule would amend Appendix B to Part 741 – Loan Workouts, Nonaccrual Policy, and Regulatory Reporting of Troubled Debt Restructured Loans. The Board has determined … Read More