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
Statement Regarding the Provision of Financial Products and Services to Consumers with Limited English Proficiency
The CFPB released a Statement encouraging financial institutions to better serve consumers with limited English proficiency (LEP) and to provide principles and guidelines to assist financial institutions in complying with the Dodd-Frank Act, the Equal Credit Opportunity Act, and other applicable laws. In publishing the Statement, the Bureau seeks to: (1) promote access to financial products for all consumers; (2) … Read More
2021 Washington Legislative Session
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
Federal Credit Unions and Community Charter Conversions and Expansions
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
Federal Credit Unions and Underserved Area Expansions
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
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
Proposed Rule – Computer-Security Incident Notification Requirements
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
Updated 314(b) Fact Sheet
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 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
November’s Regulatory Recap
November’s Regulatory Recap is now available here. Let us know if we can help in any way. CSG will be closed December 24 & 25 for Christmas. We wish all of you a happy and healthy holiday. Please be advised that CSG provides financial services compliance audit and consulting services to our clients. The services that we provide include … Read More