Thank you! Next month marks the 10th anniversary of my joining Compliance Services Group, and I want to take a moment and thank you all for trusting us for your auditing and consulting needs. When we started in June of 2012, Northwest Compliance Group was focused on helping a limited number of Washington state institutions navigate the regulatory landscape. The … Read More
April’s Regulatory Recap
April’s Regulatory Recap is now available here. It’s a short one this month, and the only thought that is running through my head is the calm before the storm. Are you keeping up with everything that you should be? Our Weekly Rewinds, which generally come out on Tuesday morning, contains regulatory and supervisory actions for the previous week. Previous issues are … Read More
Supervisory Highlights & Overdraft Programs
The FDIC published the latest version of Consumer Compliance Supervisory Highlights which provides an overview of compliance activities and issues identified through FDIC examinations. These Supervisory Highlights should be a required read for all compliance or risk-management staff in any financial organization. With the increased focus on junk fees and overdraft programs, one area in this issue that caught our … Read More
March 2022 Regulatory Recap
March’s Regulatory Recap is now available. It contains important important news and updates from the regulators. During March, the CFPB had quite a bit to say about fairness, discrimination, and junk fees. Take a look, and let us know if you have any questions. The FDIC published the latest issue of it Consumer Compliance Supervisory Highlights. This is always a … Read More
ECOA
In February, the NCUA issued Letter to Credit Unions 22-CU-04, Equal Credit Opportunity Act Nondiscrimination Requirements. With the CFPB’s increased focus on unfair discrimination, a deeper dive into the Letter is appropriate. The Letter summarizes general nondiscrimination requirements under the Equal Credit Opportunity Act (ECOA) relating to marital status, ages, income consideration, redlining, and indirect lending. The ECOA prohibits discrimination … Read More
Bank Secrecy Act Violations Can Be Costly
Recently, FinCEN and the OCC assessed a $140,000,000 civil money penalty against USAA Federal Savings Bank for alleged ongoing compliance deficiencies in its Bank Secrecy Act program. There were a number of triggers that lead up to the assessment, with many relating to the compliance department not keeping up with USAA’s rapid growth. Institutions should review the Assessment, and compare … Read More
What Is Unfair?
Updated UDAAP Focus The CFPB has increased its focus on unfair discrimination in the financial markets. It has published an updated exam manual for evaluating UDAAPs for both deposit and loan products. In examinations, the CFPB will be looking at financial institutions decision making in advertising, pricing, and other areas to ensure that institutions are appropriately testing for and eliminating … Read More
February 2022’s Regulatory Recap
February’s Regulatory Recap is now available. February did not have many new or proposed regulations issued, but there was a lot of guidance documents issued from the CFPB and other regulatory agencies included in the Regulatory Recap. Get On Our Audit Schedule Now We are quickly filling up our audit schedule for 2022. While we are continuing to provide remote … Read More
Regulation E Prohibitions
The CFPB recently issued a Compliance Bulletin reminding providers of the Regulation E prohibitions against requiring prepaid cards as the sole method for distributing government benefits. The Electronic Fund Transfer Act and its implementing Regulation E, state that people cannot be forced to receive government benefits at a specific financial institution as a condition of receiving the benefits. The rule … Read More
January 2022 Regulatory Recap
January’s Regulatory Recap is now available. It contains regulatory updates, new guidance released, status on Washington State legislative activities, and other actions that may impact your institution. 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 … Read More