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

Remittance Transfers

Unless the CFPB extends or removes the expiration of allowing estimates for remittance transfers, financial institutions will need to make sure their disclosures reflect the actual terms of any remittance transfer. Remind me The requirements for remittance transfer disclosures, under Regulation E, include the ability to estimate certain information included on the pre-payment, receipt, or combined disclosures required for remittance … Read More

September’s Regulatory Recap

September’s Regulatory Recap is now available here.  If you have any 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.  … Read More

June’s Regulatory Recap

June’s Regulatory Recap is now available.  It includes the legislative update for Washington and Oregon, along with a recap of proposed and final rules from D.C.  Let us know if you have any questions, or if we can help in any way. Law-Related Services Disclaimer.  Please be advised, CSG provides financial services compliance audit and consulting services to our clients.  … Read More

Consumer Compliance Supervisory Highlights

Earlier this month, the FDIC released the inaugural issue of Consumer Compliance Supervisory Highlights. The Highlights are intended to provide the public and supervised institutions with information and observations related to the FDIC’s supervisory activities. It also includes a high-level overview of identified consumer compliance issues. This is a great read for anyone in a compliance-related position, not just those … Read More

May’s Regulatory Recap

May’s Regulatory Recap is now available.  It includes the legislative update for Washington and Oregon, along with a recap of proposed and final rules from D.C.  Let us know if you have any questions, or if we can help in any way. Law-Related Services Disclaimer.  Please be advised, CSG provides financial services compliance audit and consulting services to our clients.  … Read More

Permissible Purpose & No Other Purpose

Last week, I received a letter from my credit union stating: “Because of your excellent credit record we’re increasing the limit on your credit card.” This got me thinking about whether the institution had a permissible purpose to review my credit. Section 604 of the Fair Credit Reporting Act requires that credit bureaus (credit reporting agencies, or CRAs) must have … Read More

A Framework for OFAC Compliance

On May 2, the Office of Foreign Assets Control published A Framework for OFAC Compliance Commitments. The Framework includes an expected Sanctions Compliance Program (SCP) that institutions should consider when developing their own risk-based OFAC compliance program. There is no “one size fits all” SCP for institutions, and each institution should establish a risk-based program based on the institution’s size … Read More