February 2023’s Regulatory Recap

February 2023’s Regulatory Recap is now available here. The Regulatory Recap includes FinCEN guidance on Mail Theft-Related Check Fraud, a proposed rule from the U.S. Treasury on requiring institutions to use the Treasury Check Verification System to verify that Treasury checks are both authentic and valid before negotiating, and the final NCUA Rule on Reportable Cycber Incidents, among other items.

In February, the CFPB ordered TitleMax (TMX Finance) to pay a $10 million civil money penalty and provide $5.05 million in redress to consumers for violations of the Military Lending Act by extending prohibited title loans to military families and, oftentimes, by charging nearly three times over the 36% annual interest rate cap. The CFPB reports that TitleMax tried to hide its unlawful activities by, among other things, altering the personal information of military borrowers to circumvent their protected status.

If you are concerned about your institution’s compliance with the Military Lending Act, Servicemembers Civil Relief Act, or any other regulatory requirements, contact us. We offer numerous compliance reviews and regulatory consulting on most issues that your institution may face. We can help you ensure that you are compliant with the requirements.


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 employees are lawyers with an active bar license but are NOT engaged in the private practice of law, that Rule requires us to make disclosures clarifying that the services we perform may be law-related services, but they are not legal services.  Because they are not legal services, those services and our relationship will not be governed by the Rules of Professional Conduct that guide the client-lawyer relationship, such as rules applicable to privileged communications and prohibitions of conflicts of interest.  Notwithstanding this disclaimer, we will continue to govern our relationship with you using reasonable ethical and professional standards that are expected to meet your expectations.


For those of you who follow my grandbaby updates, Baby Ella came a few weeks early. Mom and Ella are both doing great.

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