Sometimes it adds up

Penalties can add up quickly for ineffective vendor oversight of an insufficient compliance management system. The OCC hit Morgan Stanley with a $60,000,000 civil penalty for not having proper oversight of decommissioning two data centers and deficiencies in vendor oversight.  From the Consent Order: “In 2016, the Bank failed to exercise proper oversight of the decommissioning of two Wealth Management … Read More

RESPA FAQs

On October 7, the CFPB released a set of Frequently Asked Questions (FAQs) discussing topics under the Real Estate Settlement Procedures Act (RESPA) and Regulation X. The FAQs provide an overview of the provisions in RESPA Section 8 (and the respective sections in Regulation X), and they address the application of these provisions to gifts and promotional activities and also … Read More

NCUA Examiner’s Guide & COVID-19

While we are all getting tired of hearing “COVID-19” multiple times a day, this time it may help you when examiners come to visit.  On June 30, the NCUA updated its Examiner’s Guide to include a section on COVID-19. The section begins with “The COVID-19 pandemic may have a lasting impact on credit unions’ financial and operational conditions. Examiners should … Read More

September’s Regulatory Recap

September’s Regulatory Recap is now available here.  Let us know 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 Professional Conduct governing lawyers.  Since some … Read More

August Regulatory Recap

August’s Regulatory Recap is now available here.  Let us know 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 Professional Conduct governing lawyers.  Since some … Read More

Payday Loans

On July 7, 2020 the CFPB issued a Final Rule to amend its requirements regarding Payday, Vehicle Title, and Certain High-Cost Installment Loans (12 CFR 1041).  We blogged about the proposed rule and history of the regulation last year. The 2017 Rule had two primary parts – the “Mandatory Underwriting Provisions” (effective 11/19/2020) and the “Payment Provisions” (effective 08/19/2019). The … Read More

June’s Regulatory Recap

June’s Regulatory Recap is now available here.  Let us know 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 Professional Conduct governing lawyers.  Since some of our … Read More

Loans in Areas Having Special Flood Hazards; Interagency Questions and Answers Regarding Flood Insurance

We have reprinted the Q&As from the agencies (OCC, FRB, FDIC, FCA, & NCUA) proposed revamping of the Interagency Questions and Answers Regarding Flood Insurance.  (We did not include the footnotes, but they are available on the linked document.) The questions and answers are broken down by: Determining the Applicability of Flood Insurance Requirements for Certain Loans [Applicability] Exemptions From … Read More

May’s Regulatory Recap

May’s Regulatory Recap is now available here.  Let us know 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 Professional Conduct governing lawyers.  Since … Read More

The Pandemic and the Compliance Department—Social Distancing Means Changing Risks

With the rampant fraud associated with the pandemic, the institution’s compliance staff may be considered the unsung heroes of the institution.  Along with protecting the institution from steep fines and regulatory violations, the Bank Secrecy Act (BSA) staff protect the institution and customers by identifying and stopping illicit activity. Even with the stay at home orders, these responsibilities continue. With … Read More