Alternative Data in Credit Underwriting

The Federal Reserve, CFPB, FDIC, NCUA, and OCC released an Interagency Statement on the Use of Alternative Data in Credit Underwriting.  The statement focuses on the consumer protection implications of the use of alternative data (information not typically found in a credit report) in underwriting, while highlighting potential benefits and risks associated.  One method of alternative data included in the … Read More

CFPB Extends the 500 open-end lines of credit threshold to January 1, 2022

On October 10, 2019, the CFPB announced that it issued a final rule extending the current temporary threshold of 500 open-end lines of credit for open-end institutional and transactional coverage. For data collection years 2020 and 2021, financial institutions that originated fewer than 500 open-end lines of credit in either of the two preceding calendar years will not need to … Read More

September’s Regulatory Recap

September’s Regulatory Recap is now available here.  If you have any 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.  … Read More

June’s Regulatory Recap

June’s Regulatory Recap is now available.  It includes the legislative update for Washington and Oregon, along with a recap of proposed and final rules from D.C.  Let us know if you have any questions, or if we can help in any way. Law-Related Services Disclaimer.  Please be advised, CSG provides financial services compliance audit and consulting services to our clients.  … Read More

Consumer Compliance Supervisory Highlights

Earlier this month, the FDIC released the inaugural issue of Consumer Compliance Supervisory Highlights. The Highlights are intended to provide the public and supervised institutions with information and observations related to the FDIC’s supervisory activities. It also includes a high-level overview of identified consumer compliance issues. This is a great read for anyone in a compliance-related position, not just those … Read More

Delayed Final Payday Rule

On June 6, 2019, the CFPB issued the latest final Payday Lending Rule formally delaying the compliance dates for the mandatory underwriting provisions and making technical corrections to the payment provisions of the original Rule.  The compliance dates are set out in a new section, §1041.15, of the Rule.  The Executive Summary notes that the Bureau “continues to consider comments … Read More

May’s Regulatory Recap

May’s Regulatory Recap is now available.  It includes the legislative update for Washington and Oregon, along with a recap of proposed and final rules from D.C.  Let us know if you have any questions, or if we can help in any way. Law-Related Services Disclaimer.  Please be advised, CSG provides financial services compliance audit and consulting services to our clients.  … Read More

Permissible Purpose & No Other Purpose

Last week, I received a letter from my credit union stating: “Because of your excellent credit record we’re increasing the limit on your credit card.” This got me thinking about whether the institution had a permissible purpose to review my credit. Section 604 of the Fair Credit Reporting Act requires that credit bureaus (credit reporting agencies, or CRAs) must have … Read More

A Framework for OFAC Compliance

On May 2, the Office of Foreign Assets Control published A Framework for OFAC Compliance Commitments. The Framework includes an expected Sanctions Compliance Program (SCP) that institutions should consider when developing their own risk-based OFAC compliance program. There is no “one size fits all” SCP for institutions, and each institution should establish a risk-based program based on the institution’s size … Read More

April’s Regulatory Recap

April’s Regulatory Recap is now available.  It includes the legislative update for Washington and Oregon, along with a recap of proposed and final rules from D.C.  Let us know if you have any questions, or if we can help in any way. Law-Related Services Disclaimer.  Please be advised, CSG provides financial services compliance audit and consulting services to our clients.  … Read More