August’s Regulatory Recap

It was a quiet month on the legislative front, and our monthly recap is available here.  If you have any questions, 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 … Read More

July’s Regulatory Recap

July’s Regulatory Recap is now available at https://complianceservicesgroup.com/wp-content/uploads/2019/08/REGULATORY-RECAP-July-2019.pdf. Also, as a reminder, the private flood insurance requirements went into effect on July 1, 2019.  We have received a number of questions on the requirements, and have blogged about it here.  If you have questions on it, or any other regulatory issues, let us know.   Law-Related Services Disclaimer.  Please be advised, … Read More

Updates to Washington Trust Institutions Act – Effective July 28, 2019

CSG’s Senior Compliance Consultant, Ali Higgs, sent the following notice to our trust company clients earlier this week. Provided below is a copy for your convenience. If you are a trust company looking for consulting or auditing services, please message us at contactus@complianceservicesgroup.com or call us at (360) 943-7137. Dear Xxxx: As you may be aware, the Washington State Department … Read More

1041 Payday, Auto Title, and Balloon-Payment Loans Rule

On October 5, 2017, the CFPB released its anticipated 1690-page Rule regarding payday, auto title, and balloon-payment loans.  The Rule, while pared down from the June 2016 CFPB’s proposed rule, still covers the ability-to-repay and underwriting requirements, payment restrictions and requirement, and new information reporting for covered loans.  (A version of the Rule, with Official Interpretations incorporated is available here.) … Read More

WF Sales Practices Investigation Report

Wells Fargo released their Independent Directors of the Board of Wells Fargo & Company Sales Practices Investigation Report.  The report is a recommended read for anyone involved, including the board of directors, with setting, maintaining, or reviewing incentive programs for the credit union. From the report, the principal findings include: The root cause of sales practice failures was the distortion of … Read More

August Compliance Recap

August’s compliance recap, with a summary of regulatory issues that might impact the credit union, is available here.

Proposed Amendments to Regulation Z Mortgage Disclosure Requirements

The CFPB issued proposed changes to amend the KBYO/TRID rules of Regulation Z.  The CFPB states that the proposed amendments memorialize its informal guidance on various issues and includes clarifications and technical amendments.  There are a number of proposed changes in proposal, but are not intended to revisit major policy decisions so soon after the October 2015 effective date. Comments … Read More

Proposed Payday Loan Rule – Part 1

The CFPB released its Proposed Payday, Vehicle Title, and Certain High-Cost Installment Loans Rule on June 2, in coordination with a field hearing on these small-dollar loans.  The 1333 page proposal aims to end payday debt traps, where borrowers seeking a short-term cash fix are saddled with loans they cannot afford and sink into long-term debt. Because of the scope … Read More

BSA Violations

FinCEN’s penalty assessment against Gibraltar Private Bank reads like a Stephen King novel for BSA compliance officers. The ongoing deficiencies and either the willful blindness or ignorance by Gibraltar caused me heartburn just reading the assessment report. Gilbraltar’s issues have been ongoing since at least 2010, when the OCC first warned Gibraltar of its BSA deficiencies. A Consent order was … Read More