On August 3, 2020, the Financial Crimes Enforcement Network (FinCEN) published three new Frequently Asked Questions (FAQs) regarding Customer Due Diligence (CDD) requirements for financial institutions. The new FAQs clarify the regulatory requirements related to: Obtaining customer information; Establishing a customer risk profile; and Performing ongoing monitoring of the customer relationship. The new FAQs are in addition to those that were published on: July 19, 2016; and April 3, 2018. For further information regarding customer
On August 3 the Federal Financial Institutions Examination Council (FFIEC) issued a statement setting forth prudent risk management and consumer protection principles for financial institutions to consider while working with borrowers as initial coronavirus-related loan accommodation periods come to an end and they consider additional accommodations. The COVID event has had a significant adverse impact on consumers, businesses, financial institutions, and the economy. To address some of these impacts, the Coronavirus Aid, Relief, and Economic Security
The Electronic Code of Federal Regulations (eCFR) is a web version of the Code of Federal Regulations (CFR) that is updated daily to better reflect its current status. It has been a valuable compliance research tool since its inception. Recently the eCFR has been updated (currently in beta testing) to provide the capability to explore the Code of Federal Regulations at a point in time. With the system you can: View and search the current
On July 21, 2020 the Consumer Financial Protection Bureau (CFPB) began the annual process of updating regulatory thresholds by publishing a final rule revising certain dollar amounts in Regulation Z, based on the annual percentage change reflected in the Consumer Price Index (CPI) in effect on June 1, 2020. For open-end consumer credit plans under the CARD Act amendments to TILA ( 1026.52(b)(1)(ii)(A) and (B)), the adjusted dollar amount in 2021 for the safe harbor for
On July 7, 2020, the Consumer Financial Protection Bureau (CFPB) published a final rule, and related materials, related to the Payday lending and other small dollar products. The Payday Lending rules have been unfolding for several years. The final rule, implemented as Regulation OO, rescinds the mandatory underwriting provisions of the 2017 rule after re-evaluating the legal and evidentiary bases for these provisions and finding them to be insufficient. The final rule does not rescind
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