Section 1033 – Consumer Rights to Access Information ANPR

The CFPB released an Advance Notice of Proposed Rulemaking regarding consumer access to financial records.  The ANPR seeks comments and information on costs and benefits of consumer data access, competitive incentives, standard-setting, access scope, consumer control and privacy, and data security and accuracy.  The comment period will be for 90 days after publication in the Federal Register. The ANPR comes … Read More

October is National Cybersecurity Awareness Month

Since October is National Cybersecurity Awareness Month, FinCEN and OFAC have published advisories aiming to increase cybersecurity awareness and aid institutions in responding and reporting incidents. The FinCEN Advisory – Advisory on Ransomware and the Use of the Financial System to Facilitate Ransom Payments The advisory provides information on: (1) the role of financial intermediaries in the processing of ransomware … Read More

July’s Regulatory Recap

July’s Regulatory Recap is now available here.  Let us know if you have questions or 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 … Read More

FAQs on Changes to Regulation D

The Federal Reserve posted additional Q&As relating to their recent rule eliminating the six-per-month convenient withdrawal limitations on savings accounts. Savings Deposits Frequently Asked Questions What is the definition of a “savings deposit” in Regulation D? A “savings deposit” is a deposit or account, such as an account commonly known as a passbook savings account, a statement savings account, or … Read More

Consumer Compliance Outlook

The Federal Reserve issued its first 2020 issue of its Consumer Compliance Outlook. As always, the issue is a good resource for compliance folks. It contains information on regulatory updates, federal court opinions, and commonly cited violations. Included in the violations are violations regarding: spousal signature requirements under Regulation B and evidence of joint intent – especially conflicts between community … Read More

Remittance Transfer Rule

On May 11, the CFPB issued its Final Rule on Regulation E’s remittance transfers requirements, effective July 21, 2020. In advance of the expiration of a statutory exception in July 2020, the Final Rule amendments allow financial institutions to provide estimates of certain fees and the exchange rates related to remittance transfers if they meet certain conditions. The Final Rule … 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

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

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