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
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
Small Business Lending Data Collection Under the Equal Credit Opportunity Act
On September 1, 2021, the CFPB published proposed rulemaking on small business lending data collection. The proposal would require covered financial institutions to annually collect and report to the Bureau data on credit applications for small businesses, including those that are owned by women or minorities. The proposed rule is 918 pages long. The CFPB also provides a table of … Read More
CFPB announces new requirements for submitting credit card agreements
Last Friday, the CFPB provided information on new data submission requirements for uploading credit card agreements to the CFPB. We have reprinted the bulletin below for your convivence. Credit card issuers who are required to make quarterly credit card submissions to the Bureau pursuant to 12 CFR 1026.58(c) – 10,000 or more open credit card accounts as of the last … Read More
June’s Regulatory Recap
June’s Regulatory Recap is now available here. Let us know if we can help in any way. Have you seen our Weekly Rewinds? Past editions are available on our Resources page. 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 … Read More
July’s Regulatory Recap
July’s Regulatory Recap is now available here. Let us know if you have questions or 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 … Read More
Consumer Compliance Outlook
The Federal Reserve issued its first 2020 issue of its Consumer Compliance Outlook. As always, the issue is a good resource for compliance folks. It contains information on regulatory updates, federal court opinions, and commonly cited violations. Included in the violations are violations regarding: spousal signature requirements under Regulation B and evidence of joint intent – especially conflicts between community … Read More
February’s Regulatory Recap
February’s Regulatory Recap is now available here. Let us know if you have questions, or if we can be of any service. 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 … Read More
CFPB Supervisory Highlights – Winter 2020… and how CSG can help
In February, the CFPB released its 21st Supervisory Highlights Report. This report covered findings identified in examinations conducted by the CFPB between April 2019 and August 2019. Areas included in the report include mortgage servicing, payday lending (including general Regulation Z requirements), debt collection, and student loan servicing. Mortgage Servicing Highlights Regulation X violations discussed in the report include failing … Read More
November’s Regulatory Recap
November’s Regulatory Recap is now available here. If you have questions, please 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 of the Rules of Professional Conduct governing lawyers. Since … Read More