Category Archive

If your institution participated in the Small Business Administration’s (SBA) Paycheck Protection Program (PPP) loan program: Do you have nagging concerns that your PPP loans are not fully compliant with the ever-changing regulations? Do you worry that in a rush to make PPP loans your institution may have overlooked potential regulatory and risk management pitfalls? Do you have uncertainty that … Read More

On January 9, 2021 FinCEN, along with the Federal Reserve, FDIC, NCUA, OCC issued Answers to Frequently Asked Questions Regarding Suspicious Activity Reports and Other Anti-Money Laundering Considerations for financial institutions. We have reprinted the questions below.  The Guidance from FinCEN also includes numerous citations not included below.   Question 1: Requests by Law Enforcement for Financial Institutions to Maintain … Read More

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

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

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