The Blog

The Federal Reserve, FDIC, FinCEN, NCUA and OCC issued a fact sheet clarifying that compliance efforts to meet Bank Secrecy Act due diligence requirements for customers that are charities and other nonprofit organizations should be based on the money laundering risks posed by the customer relationship. The fact sheet highlights the importance of legitimate charities and nonprofit organizations having access … Read More

The Financial Stability Board (FSB) published a discussion paper titled Regulatory and Supervisory Issues Relating to Outsourcing and Third-Party Relationships.  The paper builds on the FSB’s 2019 report Third-Party Dependencies in Cloud Services and a survey conducted during the first quarter of 2020 on the existing regulatory and supervisory landscape related to outsourcing and third-party risk management. The paper states: … Read More

On October 30, 2020, the Consumer Financial Protection Bureau (Bureau) issued a final rule to restate and clarify prohibitions on harassment and abuse, false or misleading representations, and unfair practices by debt collectors when collecting consumer debt. The rule focuses on debt collection communications and gives consumers more control over how often and through what means debt collectors can communicate with … Read More

The CFPB’s November Quarterly Consumer Credit Trends report examines how often lenders report, or furnish, information on borrowers’ actual payment to nationwide consumer reporting agencies.  The report finds that actual payment furnishing for installment loan products including mortgages, auto, and student loans has steadily increased between 2012 and 2020.  Over the same period, actual payment furnishing for credit card and … Read More

The Office of the Comptroller of the Currency (OCC) published its Fall 2020 Semiannual Risk Perspective.  Naturally, COVID-19 is a large factor on the risk environment for financial institutions.  These risks include credit risks and consumers’ ability to service debts, financial performance in a long-term low-rate environment, cybersecurity risks from altered work environments, and compliance risks with institutions trying to … Read More

On October 23, 2020 the Financial Action Task Force (FATF) updated its list of jurisdictions with strategic deficiencies in their regimes to counter money laundering, terrorist financing, and proliferation financing.  The change may affect financial institutions’ obligations and risk-based approaches with respect to relevant jurisdictions. In Summary: Identified high-risk jurisdictions remain the same as the FATF’s February 2020 statement. Identified … Read More

On October 30, 2020, the Consumer Financial Protection Bureau (CFPB) issued a final rule to restate and clarify prohibitions on harassment and abuse, false or misleading representations, and unfair practices by debt collectors when collecting consumer debt. The rule focuses on debt collection communications and gives consumers more control over how often and through what means debt collectors can communicate … Read More

October’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 some … Read More

The Federal Reserve, Office of the Comptroller of the Currency (OCC), and the Federal Deposit Insurance Corporation (FDIC) issued an interagency paper, Sound Practices to Strengthen Operational Resilience, which describes sound practices drawn from existing regulations and guidance for individual national banks, state member banks, state nonmember banks, savings associations, U.S. bank holding companies, and savings and loan holding companies … Read More