October 28, 2026
Your Compliance Officer gives notice. Your Information Security Officer unexpectedly retires. Who takes over tomorrow? Who communicates with examiners, prepares Board reports, manages risk assessments, tracks corrective actions, and oversees [...]
October 27, 2026
Financial institutions and mortgage loan originators should be aware that the annual NMLS renewal period runs from November 1 through December 31. Financial institutions with registered mortgage loan originators are [...]
October 22, 2026
October is Cybersecurity Awareness Month, and community banks are placing a greater emphasis on investing in firewalls, endpoint protection, email filtering, and monitoring tools. But criminals know that the easiest [...]
October 20, 2026
FinCEN recently issued a Financial Trend Analysis and alert on digital asset investment scams connected to overseas scam centers. Its review of 33,904 BSA reports filed from September 8, 2023, [...]
October 15, 2026
On September 8, 2026, the FDIC, along with FinCEN and other federal banking agencies, issued new FAQs on using state-issued mobile driver’s licenses and other government-issued verifiable digital credentials to [...]
October 14, 2026
On September 10, 2026, the U.S. Department of the Treasury announced new sanctions under Operation Economic Outcast targeting individuals and entities accused of supporting Kata’ib Hizballah, Hizballah, and Iran’s sanctions-evasion [...]
October 8, 2026
On September 9, 2026, OFAC updated several Frequently Asked Questions (FAQs) and added two new FAQs related to the licensing process. The changes are primarily housekeeping and clarification updates covering [...]
October 6, 2026
On September 10, 2026, the FDIC, Federal Reserve, and OCC issued an interim final rule, effective immediately upon publication, expanding eligibility for the 18-month examination cycle for certain insured depository [...]
October 1, 2026
On September 9, 2026, the U.S. Department of the Treasury announced that FinCEN had identified approximately $17.5 billion in suspicious financial activity potentially linked to health care fraud. FinCEN’s Financial [...]
September 22, 2026
On September 8, 2026, FinCEN issued an alert to help financial institutions identify and report procurement networks supporting Iran’s commercial aviation industry. The alert includes red flag indicators and suspicious [...]
September 17, 2026
On September 3, 2026, FinCEN published a financial trend analysis and alert urging financial institutions to remain vigilant for digital asset investment scams, commonly referred to as “pig butchering,” “romance [...]
September 16, 2026
On September 2, 2026, FinCEN renewed its Southwest Border Geographic Targeting Order (GTO) for certain money services businesses (MSBs) located in designated ZIP Codes in New Mexico and Texas. Effective [...]
September 15, 2026
On September 2, 2026, the Federal Reserve, FDIC, NCUA, OCC, and FinCEN issued a joint statement clarifying SAR confidentiality requirements when communicating with customers regarding potentially fraudulent transactions, other suspicious [...]
September 3, 2026
Community banks may notice changes in future exam reports following a recent FDIC final rule that eliminates Matters Requiring Board Attention (MRBAs) and Supervisory Recommendations (SRs). The FDIC has also [...]
September 1, 2026
FinCEN issued a final rule on August 11, 2026, effective August 14, 2026, that permanently removes the requirement for U.S. companies and U.S. persons to report beneficial ownership information (BOI) [...]
August 27, 2026
If you are searching for fresh topics to cover in this year’s IT security awareness training for your institution, Shadow AI is one to consider. Shadow AI is the unsanctioned [...]
July 30, 2026
On July 24, 2026, FinCEN issued an alert urging financial institutions to watch for and report fraud schemes involving federal student aid programs. Fraud rings are using stolen or complicit [...]
July 28, 2026
On July 13, 2026, the FDIC, OCC, and NCUA issued guidance reminding financial institutions to consider the risks associated with lending to individuals who are not legally authorized to work [...]
July 23, 2026
Nebraska Governor Jim Pillen approved LB 838 on April 14, 2026, strengthening Nebraska’s existing authority for addressing suspected financial exploitation of vulnerable and senior adults. The law gives community banks [...]
July 22, 2026
LB 717 created a new Net Tangible Benefit Disclosure requirement for certain refinance transactions, and we wanted to provide clarification regarding who is required to provide this disclosure. The new [...]
July 21, 2026
Most banks have started discussing artificial intelligence, implementing policies, or at least considering how AI may fit into their operations. However, a recent incident involving a community bank serves as [...]
July 16, 2026
On June 30, 2026, the FDIC, FRB, and OCC released the 2026 list of distressed or underserved nonmetropolitan middle-income geographies where certain bank activities may be eligible for Community Reinvestment [...]
July 14, 2026
On June 30, 2026, FinCEN issued an alert to assist financial institutions in identifying and reporting suspicious activity connected to fuel smuggling and Mexican tax evasion schemes on the U.S. [...]
July 8, 2026
OFAC has launched a new online ‘reconsideration portal’ where requests to be removed from an OFAC sanctions list can be submitted. The portal is designed to streamline the delisting process by [...]
June 30, 2026
The FFIEC has announced the release of 2025 Home Mortgage Disclosure Act (HMDA) mortgage lending data. The release includes the 2025 Snapshot National Loan-Level Dataset, updates to the Dynamic National [...]
June 25, 2026
In recognition of Elder Abuse Awareness Month, this month’s CCI IT Update is focusing on strengthening employee awareness of impostor phone scams that frequently target older adults. These scams remain [...]
June 24, 2026
On June 12th, FinCEN issued guidance clarifying how financial institutions can share information with one another regarding suspected fraud under section 314(b) of the USA PATRIOT Act. The guidance states [...]
June 17, 2026
On June 2, 2026, the Federal Reserve, FDIC, and OCC announced that they removed additional references to reputation risk from supervisory materials as part of an effort to clarify that [...]
June 15, 2026
June 15th, World Elder Abuse Awareness Day, is a reminder to financial institutions of their responsibility to protect and support vulnerable customers and help prevent devastating losses before they occur. [...]
June 11, 2026
FinCEN issued an advisory on June 5, 2026, reminding financial institutions of the risks presented by the unlawful employment of illegal aliens. The advisory is intended to help institutions identify [...]
June 9, 2026
On May 15, 2026, the OCC issued two final rules clarifying national banks’ and federal savings associations’ authority over real estate lending escrow accounts. The rules reaffirm institutions’ ability to [...]
June 4, 2026
On May 11, 2026, FinCEN issued an alert to assist financial institutions in identifying and reporting activity associated with the Islamic Revolutionary Guard Corps (IRGC), a powerful branch of Iran’s [...]
June 2, 2026
On May 11, 2026, FinCEN issued a Notice urging financial institutions to remain vigilant for potential human trafficking activity associated with the 2026 FIFA World Cup, which will be hosted [...]
May 14, 2026
On May 6, 2026, FinCEN updated its Q&As on the Customer Due Diligence (CDD) Rule to align with its February 13, 2026, exceptive relief order and consolidate prior FAQ issuances. The update combines FAQs from [...]
May 12, 2026
The CFPB issued a final rule on May 1, 2026, revising its small business lending data collection requirements under Section 1071 (Regulation B). The rule narrows the 2023 framework and establishes a [...]
May 7, 2026
FinCEN released its Fiscal Year 2025 (FY25) Year in Review, detailing its initiatives, outcomes, and strategic priorities in safeguarding the U.S. financial system against illicit activity. The report highlights FinCEN’s [...]
May 5, 2026
On April 22, 2026, the CFPB issued a final rule amending Regulation B (ECOA) provisions regarding disparate impact, discouragement of applicants or prospective applicants, and special-purpose credit programs. This final [...]
April 30, 2026
Earlier this month, the FDIC and the OCC issued a final rule prohibiting the use of “reputation risk” as a standalone basis for bank supervision and enforcement, effective June 9, [...]
April 28, 2026
The Federal Reserve has published the 2026 Consumer Compliance Outlook, summarizing recent supervisory findings and trends from Federal Reserve examinations of state member banks. This edition of Consumer Compliance Outlook [...]
April 23, 2026
FinCEN issued a proposed rule on April 7, 2026, intended to fundamentally reform financial institutions’ anti-money laundering and countering the financing of terrorism (AML/CFT) programs under the Bank Secrecy Act [...]
April 22, 2026
On April 10, 2026, the FDIC issued Financial Institution Letter (FIL)‑14‑2026 rescinding its supervisory guidance on multiple re‑presentment non‑sufficient funds (NSF) fees, effective immediately. This rescission eliminates both the 2023 [...]
April 21, 2026
On March 31, 2026, OFAC released new guidance highlighting the growing use of sham transactions. These transactions are transfers that appear legitimate on paper but do not extinguish a blocked [...]
April 16, 2026
The OCC issued two rules to reduce the regulatory burden on community banks by eliminating duplicative data collection requirements and expanding eligibility for streamlined licensing and filing procedures. First, the [...]
April 15, 2026
The FDIC published its Spring 2026 edition of Consumer Compliance Supervisory Highlights, which summarizes consumer compliance exam findings identified during recent FDIC compliance exams. The publication highlights recurring issues, emerging trends, and [...]
April 14, 2026
The FFIEC recently updated its BSA/AML Examination Manual to remove references to “reputational risk.” While the wording has changed, the underlying BSA/AML requirements remain the same. This change stems from [...]
April 2, 2026
On March 30, 2026, FinCEN issued an advisory warning financial institutions about increasing fraud schemes targeting Medicare, Medicaid, and other federal and state health care benefit programs. FinCEN notes that [...]
April 1, 2026
On March 13, 2026, the White House issued an Executive Order titled “Promoting Access to Mortgage Credit.” The order directs federal regulators to review and, if necessary, revise regulatory requirements [...]
March 25, 2026
The FDIC and OCC have released their Community Reinvestment Act (CRA) examination schedules for the second and third quarters of 2026. The schedules identify institutions expected to undergo CRA evaluations [...]
March 24, 2026
CISA and Microsoft recently issued joint guidance following the politically motivated cyberattack on Stryker in March 2026. The threat actor identified as the Iran‑linked group Handala gained privileged access to [...]
March 4, 2026
With the upcoming time change, now is a good opportunity to set yourself a reminder for Monday, March 9th, to review your Loan Estimate disclosures to ensure the correct time [...]
February 26, 2026
On February 13, 2026, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) launched a new webpage to receive whistleblower tips related to fraud, money laundering, sanctions violations, [...]
February 24, 2026
NACHA 2026 ACH Fraud Monitoring, Company Entry Descriptions, Funds Availability, & IAT Definition Updates NACHA has approved several significant ACH Rule amendments taking effect in 2026 as part of its [...]
February 17, 2026
The FDIC has issued a final rule amending the FDIC Rules and Regulations governing signage requirements for insured depository institutions’ (IDIs’) digital deposit-taking channels and automated teller machines (ATMs) and [...]
February 13, 2026
On February 13, 2026, FinCEN issued exceptive relief under the 2016 CDD Rule, effective immediately, removing the requirement to identify and verify the beneficial owners of a legal entity customer [...]
February 12, 2026
The CFPB has discontinued the use of its GovDelivery email service for HMDA notifications, effective January 20, 2026. As a result, subscribers will no longer receive email alerts regarding HMDA platform updates or announcements. [...]
February 3, 2026
On January 5th, a cybersecurity company, Hudson Rock, published an article (link below) outlining how a threat actor, “Zestix,” compromised 50 major global enterprises and sold stolen credentials without using [...]
February 3, 2026
March 2, 2026, is the due date for the annual HMDA LAR submission of 2025 data for all banks subject to HMDA reporting requirements. Submission will be considered timely if received on or before [...]
January 29, 2026
FinCEN’s Anti-Money Laundering Regulations for Residential Real Estate Transfers (RRE Rule) establish nationwide reporting requirements for non-financed residential real estate transfers to legal entities or trusts. The effective date originally [...]
January 27, 2026
Compliance expectations never stand still, but some lessons never change. This special edition of our newsletter takes a sharp, data-driven look at where we see institutions most often stumble and [...]
January 23, 2026
The CFPB and the DOJ issued a joint statement in October of 2023 that cautioned lenders that creditor policies relating to an applicant’s immigration or citizenship status could raise concerns [...]
January 21, 2026
On December 30, 2025, the Federal Regulators announced the updated 2026 Community Reinvestment Act (CRA) asset-size thresholds for “small banks” and “intermediate small banks.” The CRA regulations establish the framework [...]
January 15, 2026
Does your bank offer a Home Equity Line of Credit (HELOC) program? If so, it’s important to ensure that your HELOC Program disclosures are reviewed at least annually to maintain accuracy and [...]
January 13, 2026
“Risk-Based Exams” is a phrase that has been increasingly discussed across the compliance landscape. As we move toward 2026, institutions should expect a noticeable adjustment in the Federal Reserve’s supervisory [...]
January 6, 2026
The Home Mortgage Disclosure Act (HMDA) requires certain institutions to collect and report mortgage loan data each year. One key factor is the loan volume threshold. Institutions that otherwise meet Regulation C’s [...]
January 5, 2026
In the IT world, we all know about Account Takeover, but does the rest of the bank staff? Are bank customers aware of this threat? The FBI recently released a Public [...]
December 30, 2025
Effective January 1, 2026, multiple federal consumer financial protection regulations will have updated dollar thresholds that affect coverage, disclosures, and product eligibility. These changes impact Truth in Lending (Regulation Z), [...]
December 29, 2025
President Donald Trump has signed an executive order directing the expedited reclassification of marijuana under the Controlled Substances Act. This action would move cannabis from Schedule I to Schedule III, [...]
December 22, 2025
The March 1, 2026, deadline for submitting 2025 HMDA LAR Data is quickly approaching. Prior to filing, it is best practice to complete a year-end HMDA LAR scrub. Why Complete [...]
December 18, 2025
As we head into 2026, the OCC is rolling out meaningful changes to its examination framework. The agency is shifting away from rigid, calendar-based exam cycles and checklist-driven procedures. Beginning [...]
December 17, 2025
As the year is coming to an end, we wanted to remind everyone that the annual renewal period for Mortgage Loan Originator(s) on the Nationwide Mortgage Licensing System (NMLS) is [...]
December 10, 2025
The Federal Deposit Insurance Corporation (FDIC) is extending the compliance date from March 1, 2026, to January 1, 2027, for the requirements under 12 CFR 328.5 to display the FDIC official digital [...]
December 9, 2025
While the holiday shopping season ramps up, so do threats for banks, specifically ATM threats. ATM “jackpotters” and “hook-and-chain” attackers are targeting banks across the Midwest. ATM jackpotting is a type [...]
December 5, 2025
n November 25, 2025, the Federal Deposit Insurance Corporation (FDIC) approved a final rule updating certain regulatory thresholds under 12 CFR Part 363 to reflect inflation. The changes, which take [...]
December 3, 2025
As Bank Compliance Consultants, we see many ways of setting up Compliance Management Systems (CMS). A lot of our time is spent assisting with setting up or reviewing a CMS. [...]
November 17, 2025
The CFPB has rolled out proposed revisions to the 1071 rule under the Dodd-Frank Act. Here’s a quick look at what’s changing and what information you may need to start [...]
November 12, 2025
The FDIC has announced significant updates to its Consumer Compliance Examination Manual, specifically examination schedules. These changes, effective November 7, 2025, reflect a more risk-based approach to scheduling compliance and [...]
November 10, 2025
The U.S. Mint has ceased production of new pennies following a directive from President Trump earlier this year. The final shipment of newly minted pennies was delivered in August 2025. [...]
November 4, 2025
Daylight Saving Time has officially ended, and we’ve returned to Central Standard Time (CST). Ensure that all time zone references on your Loan Estimates, when disclosing the expiration date and [...]
November 3, 2025
NACHA has approved several new rules designed to improve the efficiency and compliance of International ACH Transactions. The rules will have varying effective dates beginning in March 2026. IAT Contact [...]
October 28, 2025
Banks across Western and Southeast Nebraska are reporting new cases of attempted fraud in which individuals use fake identification to withdraw funds from home equity lines of credit (HELOCs). The [...]
October 7, 2025
As the National Flood Insurance Program (NFIP) experiences a lapse due to the ongoing government shutdown, federal banking agencies have reissued guidance reminding lenders of their flood insurance obligations. Lenders [...]
September 24, 2025
The FDIC conducts a fair lending review as part of every consumer compliance examination, evaluating the Bank’s compliance with the anti-discrimination laws and regulations, such as the Equal Credit Opportunity [...]
September 22, 2025
An Executive Order signed on August 7, 2025, titled “Guaranteeing Fair Banking for All Americans,” directs federal agencies to combat “debanking” – the denial or termination of financial services based [...]
September 18, 2025
The decision to bank marijuana-related businesses creates additional steps for banks regarding their Bank Secrecy Act (BSA) practices. In today’s economy, the number of businesses that are involved, one way [...]
September 16, 2025
The FDIC has updated the Consumer Compliance Examination Manual (CEM) effective as of August 29, 2025. This update removed all references to disparate impact in several chapters of the manual. The [...]
September 10, 2025
Business email compromise (BEC) continues to be a primary attack vector of cybercriminals. Unlike mass phishing email attacks, BEC is targeted and appears legitimate. Cybercriminals focus on executives, financial professionals, [...]
August 12, 2025
On June 27, 2025, FinCEN issued an order permitting OCC, FDIC, and NCUA-supervised institutions to collect Tax Identification Number (TIN) information from a third party rather than directly from their [...]
August 7, 2025
In May, the Board of Governors of the Federal Reserve System put out a helpful document called Cybersecurity Resources for Community Banks. Whether the Fed examines you or not, the [...]
July 23, 2025
In mid-July, the Omaha Tribe of Nebraska adopted comprehensive cannabis regulations, making it the first jurisdiction in the state to legalize and regulate both medical and adult-use cannabis fully. The [...]
July 22, 2025
The Nebraska Medical Cannabis Commission has approved emergency regulations to begin accepting medical cannabis applications. The emergency regulations largely mirror a legislative proposal that lawmakers stalled last month. The regulations [...]
July 17, 2025
On June 25, 2025, FinCEN issued orders identifying three Mexico-based financial institutions as primary money laundering concerns. These institutions were involved in illicit opioid trafficking. They collectively laundered millions of [...]
July 16, 2025
The Community Reinvestment Act (CRA) encourages banks to meet the credit needs of their local communities, including those with low- and moderate-income populations. Distressed or underserved nonmetropolitan middle-income geographies are [...]
July 14, 2025
The U.S. Treasury has announced a new FinCEN Exchange series titled “Combating and Obstructing Money Movements Associated with Narcotics and Drug Trafficking Organizations” (COMMAND) focused on combating narcotics trafficking and [...]
July 10, 2025
The Federal Financial Institutions Examination Council (FFIEC) has published data on the 2024 mortgage lending transactions submitted under the Home Mortgage Disclosure Act (HMDA). This release contains several products, such as [...]
July 2, 2025
In March of this year, the Office of the Comptroller of the Currency (OCC) announced that it would no longer examine banks for reputational risk. On June 23rd, the Federal Reserve [...]
June 25, 2025
On June 6, 2025, the Financial Crimes Enforcement Network (FinCEN) issued an Advisory on Iranian Sanctions Evasion, replacing its 2018 advisory. Additionally, OFAC issued several rounds of designations targeting Iranian [...]
June 23, 2025
June 15th was World Elder Abuse Awareness Day, serving as a reminder to financial institutions of the vital role they play in protecting older adults from financial exploitation. As trusted [...]
June 20, 2025
There has been considerable discussion around Section 1071, Small-Business Lending Data Collection Requirements and its implementation, and we finally have an update. The CFPB issued an interim final rule with [...]
June 18, 2025
A new Nebraska State Board met for the first time last week, but it won’t have time to lounge. The Nebraska Medical Cannabis Commission has less than a month to draft [...]
June 10, 2025
In April, the FDIC, Federal Reserve, and OCC, withdrew supervisory guidance, and two joint statements previously issued on crypto-asset-related activities. You can read the press release here. The agencies have advised [...]
June 9, 2025
Verizon’s annual Data Breach Investigations Report (DBIR) for 2025 was released in April, which is always interesting to read. This year, the Verizon DBIR team analyzed 22,052 real-world security incidents. [...]
May 22, 2025
OFAC has recently updated its record retention requirements. Effective March 12, 2025, this final rule extended OFAC’s recordkeeping requirements from 5 years to 10 years, specifically for transactions subject to [...]
May 20, 2025
On May 12, 2025, the CFPB formally withdrew numerous interpretive rules, policy statements, and advisory opinions, some dating back to 2011. This is a big shift in how the CFPB [...]
May 16, 2025
Return requirements for Subsection 2.13.2 of the NACHA Operating Rules state that an Originating Depository Financial Institution (ODFI) may request a Receiving Depository Financial Institution (RDFI) to return an Entry [...]
May 16, 2025
Return requirements for Subsection 2.13.2 of the NACHA Operating Rules state that an Originating Depository Financial Institution (ODFI) may request a Receiving Depository Financial Institution (RDFI) to return an Entry [...]
May 9, 2025
On May 1st, FinCEN issued an alert on Oil Smuggling Schemes on the U.S. Southwest Border Associated with Mexico-Based Cartels, warning financial institutions about the use of the U.S. financial [...]
May 6, 2025
The OCC issued a bulletin on April 8th, 2025, regarding certain name and address changes for notices required by the CRA and ECOA and for posters required by the FHA. [...]
May 2, 2025
We have been waiting for a revised SCRA Notice Disclosure since November of 2024, and it is finally here! On April 15th, the U.S. Department of Housing and Urban Development [...]
May 1, 2025
On March 26th, 2025, the U.S Department of Housing and Urban Development (HUD) issued a letter announcing that non-permanent residents will no longer be eligible for Federal Housing Administration (FHA) [...]
April 29, 2025
Reg CC funds Availability adjustments are right around the corner! In 2019, a final rule was issued that set adjustments in the dollar amounts relating to funds availability. 2020 saw [...]
April 29, 2025
Reg CC funds Availability adjustments are right around the corner! In 2019, a final rule was issued that set adjustments in the dollar amounts relating to funds availability. 2020 saw [...]
April 28, 2025
On April 8, 2025, the Office of the Comptroller of the Currency (OCC) notified Congress that it had identified a major incident resulting from a breach of the OCC’s email [...]
April 17, 2025
On March 31st, FinCEN issued an alert on Bulk Cash Smuggling and Repatriation by Mexico-Based Transnational Criminal Organizations in support of Executive Order 14157. The alert was intended to educate [...]
April 15, 2025
The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) has recently updated its record retention requirements, impacting financial institutions, businesses, and individuals subject to its regulations. Effective [...]
April 10, 2025
FinCEN issued an Advisory on the Financing of ISIS on April 1st. The advisory provided Financial Institutions with a listing of Red Flags, intended to help identify, prevent, and report [...]
April 9, 2025
A Bank should be prepared to handle complaints promptly and accurately regarding the Bank’s products, services, or how the Bank treated the customer. Complaints can be an opportunity to improve [...]
April 4, 2025
The Consumer Financial Protection Bureau (CFPB) has announced plans to initiate new rulemaking for Section 1071 of the Dodd-Frank Act, aimed at revising its small-business lending data reporting requirements. The [...]
April 2, 2025
On March 21st, 2025, FinCEN issued an interim final rule that narrowed the existing beneficial ownership reporting requirement under the Corporate Transparency Act from foreign and domestic reporting companies to [...]
March 31, 2025
Spring cleaning is here! Financial institutions should ensure their CRA public files are accurate with up-to-date information and finalized as of the April 1st deadline. You will want to ensure [...]
March 31, 2025
TD Bank, the 10th largest bank in the US, confirmed this week that a former employee had unauthorized access to and shared sensitive customer data from August to December 2022. This [...]
March 19, 2025
Daylight Savings Time (DST) was on Sunday, March 9th! That means it’s time to verify the disclosed time zone on your Loan Estimate! Your loan software may automatically update the time [...]
March 10, 2025
The Treasury Department has announced, concerning the Corporate Transparency Act, not only will it not enforce any penalties or fines associated with the beneficial ownership information reporting rule under the [...]
March 7, 2025
The FDIC has delayed the compliance date for the following provisions under its Sign and Advertising Rule: Display of the FDIC Official Sign on insured depository institutions’ digital channels Provisions [...]
March 7, 2025
The FDIC has delayed the compliance date for the following provisions under its Sign and Advertising Rule: Display of the FDIC Official Sign on insured depository institutions’ digital channels Provisions [...]
February 24, 2025
The U.S. District Court for the Eastern District of Texas has lifted a preliminary injunction removing the last legal roadblock to the enforcement of the Corporate Transparency Act (CTA). The [...]
February 11, 2025
Regulatory Freeze Memorandum On January 20, 2025, President Trump issued a 60-day regulatory freeze memorandum, pausing new and in-process regulations. The 1071 Rule is not subject to this freeze as [...]
February 7, 2025
On February 1st, 2024, and July 11th, 2024, FinCEN issued two alerts on Israeli Extremist Settler Violence Against Palestinians in the West Bank. FinCEN has rescinded both alerts. The President [...]
February 5, 2025
On November 5, 2024, Nebraska voters overwhelmingly approved two companion medical cannabis initiatives! Both measures received more than two-thirds of the vote. On December 10, 2024, Gov. Jim Pillen (R) [...]
January 28, 2025
Are your employees equipped to defend against MFA fatigue? MFA fatigue refers to a type of cyber-attack where an attacker overwhelms a user with multiple multi-factor authentication (MFA) requests, hoping [...]
January 17, 2025
The CFPB has issued a final rule amending Regulation V, which implements the Fair Credit Reporting Act (FCRA), concerning medical information. The FCRA prohibits creditors from considering medical information in [...]
January 16, 2025
Good day, lending staff! It’s that time of year again. The CFPB has issued several annual inflation adjustment final rules. See all below! Home Mortgage Disclosure (Regulation C) Adjustment to [...]
January 10, 2025
FinCEN has issued an alert (FIN-20240Alert005) to raise awareness of fraud schemes abusing FinCEN’s name, insignia, and authorities for financial gain. These FinCEN-specific fraud schemes include scams that: exploit beneficial [...]
January 6, 2025
January 9, 2025, is declared a National Day of Mourning in honor of the passing of President Jimmy Carter. For Regulations Z and CC purposes, the National Day of Mourning [...]
December 27, 2024
End of the year, last-minute update! The U.S. Court of Appeals for the Fifth Circuit reinstated the enforceability of the Corporate Transparency Act on Monday, lifting the nationwide injunction issued [...]
December 27, 2024
As of December 26, 2024, the Fifth Circuit Court of Appeals has once again placed the January deadline on hold. Please disregard the previous CCI update you received this morning. [...]
December 13, 2024
The Federal Reserve, CFPB, FDIC, FinCEN, NCUA, OCC, and state financial regulators have issued a statement providing financial institutions with examples of risk management and other practices that can effectively [...]
December 10, 2024
Thirty-eight states have now legalized either medical marijuana, recreational marijuana, or both, unlocking an entirely new, booming industry packed with businesses that will require deposit accounts, loans, and other financial [...]
December 6, 2024
A preliminary injunction has been issued, blocking enforcement of the January 1, 2025, deadline for businesses to report their beneficial owners to FinCEN. The order states that covered companies nationwide [...]
December 5, 2024
With only a few months left before your March 1st filing deadline, now is a good time to plan the year-end HMDA scrub. A HMDA Scrub compares specific data in [...]
December 2, 2024
FinCEN has issued an alert to help financial institutions identify fraud schemes associated with the use of deepfake media created with generative artificial intelligence (GenAI) tools. The alert explains typologies [...]
November 27, 2024
The CFPB has amended Appendix O to Regulation V, which implements the FCRA, to establish the maximum allowable charge for disclosures by a consumer reporting agency to a consumer for [...]
November 25, 2024
The CFPB has issued a final rule amending Regulation Z, which implements TILA, to update the dollar amounts of various thresholds that it must adjust annually to reflect the annual [...]
November 22, 2024
The CFPB has released the final rule implementing Section 1033 of the Dodd-Frank Act requiring banks with over $850 million in assets to make a consumer’s financial information available to [...]
November 21, 2024
Scammers have all kinds of high-tech options to choose from, but old-fashioned paper check scams are still a top choice for many. In one of its latest Updates, the Nebraska [...]
November 7, 2024
Central Daylight Savings Time has now ended! CST will be the abbreviation to use in our region to disclose the time zone when disclosing the date and time the interest [...]
October 31, 2024
FinCEN has issued an alert to help financial institutions identify funding streams supporting the Iran-backed Lebanese militia and U.S.-designated Foreign Terrorist Organization (FTO) Lebanese Hizballah (Hizballah). The alert supplements the information [...]
October 29, 2024
As many banks have moved off-premises with their email and Office software products to the Microsoft cloud, it may be prudent to consider some of the missteps at Microsoft when [...]
October 29, 2024
All providers of ACH services, including participating depository institutions, third-party senders, and third-party service providers, are required to conduct an annual audit of the Nacha Operating Rules and Guidelines. This [...]
October 25, 2024
The NMLS Annual Renewal Period begins on November 1st and ends on December 31st. According to federal regulations, mortgage loan originator registrants and institutions must renew their registrations annually. Once submitted [...]
October 18, 2024
The FDIC has extended the compliance date for amendments made by the final rule to Subpart A that governs the use of the official FDIC signs and insured depository institutions [...]
October 18, 2024
The FDIC has extended the compliance date for amendments made by the final rule to Subpart A that governs the use of the official FDIC signs and insured depository institutions [...]
October 9, 2024
CORRECTION! Thankfully, one of our subscribers caught our ‘OOPSIE’! In the update just sent out, we incorrectly said Reg Z and Reg M will NOT apply to consumer credit transactions and consumer [...]
October 2, 2024
The ABA Check Fraud Claim Directory has been updated and is now called the ABA Fraud Contact Directory. The enhanced resource allows banks to connect with other institutions to address [...]
September 26, 2024
With the Equifax data breach that exposed the personal information of 147 million Americans in 2017 and the NationalPublicData.com breach in headlines the past two weeks, it is safe to [...]
September 26, 2024
This cat doesn’t have nine lives. The FFIEC recently announced that its member agencies (FRB, FDIC, OCC, CFPB, NCUA, and State Liaison Committee) will sunset the Cybersecurity Assessment Tool (CAT) [...]
August 15, 2024
FinCEN has issued a notice to financial institution customers about reporting beneficial ownership information (BOI). The notice outlines the two different BOI requirements. Reporting beneficial ownership information directly to FinCEN [...]
August 5, 2024
The Regulatory Agencies have issued a joint statement to note potential risks related to arrangements between banks and third parties who deliver bank deposit products and services to end users. [...]
August 2, 2024
The Federal Agencies have jointly issued a Final Rule to implement the quality control standards mandated by the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank Act) for the [...]
August 1, 2024
On June 28, 2024, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued a Notice of Proposed Rulemaking (NPRM) proposing amendments to the anti-money laundering/countering the financing [...]
July 29, 2024
The FDIC has published Questions and Answers related to Part 328 Final Rule – the FDIC Official Signs and Advertising Requirements, False Advertising, Misrepresentation of Insured Status, and Misuse of [...]
July 26, 2024
The Regulatory Agencies have issued final Interagency Guidance on Reconsiderations of Value (ROV) of Residential Real Estate Valuations. The guidance: Describes the risks of deficient residential real estate collateral valuations [...]
July 24, 2024
FinCEN has jointly issued a Notice with OFAC and the FBI to help financial institutions identify and report suspicious activity potentially associated with timeshare fraud in Mexico. According to the [...]
July 23, 2024
The Monetary Authority of Singapore (MAS) has announced a new requirement impacting all major retail banks in the country to phase out the use of one-time passwords (OTPs) within the [...]
July 22, 2024
FinCEN previously issued an alert in February of this year related to the financing of Israeli extremist settler violence against Palestinians in the West Bank. FinCEN has now issued a [...]
July 19, 2024
The Community Reinvestment Act (CRA) encourages banks to meet the credit needs of their local communities, including low- and moderate-income communities. Distressed or underserved nonmetropolitan middle-income geographies are census tracts [...]
July 5, 2024
FinCEN has issued an advisory to alert U.S. financial institutions to new trends in the illicit fentanyl supply chain and urge vigilance in identifying and reporting suspicious activity associated with [...]
July 2, 2024
The CFPB has now confirmed the extended compliance deadlines for its Small Business Lending Data Collection rule by 290 days. To determine the Compliance Tier your institution will fall under, [...]
June 28, 2024
The AI chatbot, ChatGPT, is a LLM that you may have had bank employees ask to use at your institutions, and it may be one that you use yourself. With Artificial [...]
June 6, 2024
The FFIEC released the 2024 edition of A Guide to HMDA Reporting: Getting It Right! for Home Mortgage Disclosure Act (HMDA) in May. The guide is a resource for financial [...]
June 4, 2024
Elder Financial Exploitation (EFE) involves the illegal or improper use of an older adult’s funds, property, or assets. It is often perpetrated either through theft or scams. According to the [...]
May 31, 2024
OFAC has released an interim final rule to amend the Reporting, Procedures and Penalties Regulations to require electronic filing of certain submissions to OFAC and to describe and modify certain [...]
May 29, 2024
The Federal Reserve Board and CFPB have issued a final rule amending Regulation CC to adjust for inflation dollar amounts relating to availability of funds. Back in 2019, a rule [...]
May 22, 2024
The Federal Reserve, FDIC, and OCC have released a new guide specifically tailored for community banks. This guide is a resource that will help you develop and manage third-party risk [...]
May 21, 2024
The CFPB is extending compliance deadlines for the 1071 small business lending rule! To catch everyone up, after the CFPB issued the original ruling on March 30, 2023, a group [...]
May 8, 2024
Last week, the Federal Reserve, FDIC, and OCC released a new guide for community banks to help develop and manage third-party risk management practices. The guide reiterates that a bank’s [...]
May 2, 2024
The CFPB has released its Spring 2024 issue of Supervisory Highlights. The report details specific findings from select examinations regarding mortgage servicing completed during the 2nd, 3rd, and 4th quarters [...]
April 30, 2024
FinCEN has updated its Beneficial Ownership Information (BOI) Frequently Asked Questions to include new questions and updated information about reporting companies, beneficial ownership through trusts, and access to beneficial ownership [...]
April 23, 2024
In late March, the innovative artificial intelligence leader, OpenAI, announced a preview of what it dubbed Voice Engine, a technology that, with a 15-second audio sample, can generate natural-sounding speech [...]
April 19, 2024
FinCEN, along with the U.S. Department of State’s Diplomatic Security Service (DSS), has issued a notice to financial institutions urging them to be vigilant in identifying and reporting suspicious activity [...]
April 16, 2024
Have you updated your Bank’s Federal agency address on the Adverse Action Notice? In case you missed this, effective March 30, 2024, the Federal agency addresses should have been updated [...]
April 5, 2024
The Federal Financial Institutions Examination Council issued a statement of principles related to valuation discrimination and bias for member entities to consider in their consumer compliance and safety and soundness [...]
March 26, 2024
Last week, the Federal Reserve, FDIC, and OCC jointly issued an interim final rule extending the applicability date of specific provisions in the Community Reinvestment Act final rule issued in [...]
March 21, 2024
Tabletop exercises, sometimes called “TTXs,” are dialogue-based sessions to discuss team roles during cybersecurity, disaster, and pandemic scenarios and record bank responses to these emergencies. TTXs can add immense value [...]
March 13, 2024
The U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) has published the BOI-Access Rule Small Entity Compliance Guide (Guide). The Guide provides an overview of the Beneficial Ownership Information Access [...]
March 8, 2024
The Nebraska Banking Act section 8-143.01 has been amended to remove the requirement for Executive Officers to annually report all loans or indebtedness to the Bank’s Board of Directors. The [...]
March 6, 2024
Central Daylight Savings Time is on Sunday, March 10th! CDT will be the abbreviation to use in our region to disclose the time zone when disclosing the date and time the [...]
February 27, 2024
CCI has expanded our services and now offers IT Consulting for community banks. Customizable services include Vendor Management, Security Awareness Training, Incident Response Planning, Advisory Committee Membership, and more. You [...]
February 15, 2024
Make sure your CRA Public File is consistently updated after April 1, 2024! Why? It will now actually be PUBLIC. The Federal banking agencies adopted revisions in October 2023 to [...]
January 26, 2024
On December 12th, the Financial Crimes Enforcement Network (FinCEN) issued 18 new FAQs, providing additional guidance and information related to the beneficial ownership information reporting requirement that went into effect [...]
January 24, 2024
Congratulations! You and your BSA staff have made it through 2023! Now it is time to start tackling your “To Do List” for 2024. One of the items on this [...]
January 2, 2024
The Federal Reserve Board and the Federal Deposit Insurance Corporation have announced the updated asset size thresholds used to define “small bank” and “intermediate small bank” under their Community Reinvestment [...]
December 29, 2023
The Federal Deposit Insurance Corporation (FDIC) is amending its regulations governing the use of the official FDIC sign and insured depository institutions’ (IDIs) advertising statements to reflect how depositors conduct [...]
December 29, 2023
The Federal Deposit Insurance Corporation (FDIC) is amending its regulations governing the use of the official FDIC sign and insured depository institutions’ (IDIs) advertising statements to reflect how depositors conduct [...]
December 28, 2023
FinCEN has issued the final rule on access to beneficial ownership information (BOI). The BOI Access Rule outlines the conditions under which BOI reported to FinCEN may be disclosed to [...]
December 27, 2023
Last week, President Biden vetoed a Senate joint resolution to overturn the CFPB’s final rule implementing Section 1071 of the Dodd-Frank Act, which requires collecting and reporting credit application data [...]
December 7, 2023
In the last two years, there has been a storm of efforts for fee reform throughout the economy. The White House, Federal Trade Commission, and CFPB have launched junk fee [...]
December 1, 2023
FinCEN has extended the timeframe for companies created or registered in 2024 to report their BOI. Under the final rule, companies created or registered in 2024 now have 90 days [...]
November 28, 2023
FinCEN has issued an alert regarding fraud schemes related to the COVID-19 Employee Retention Credit. As a reminder, the Coronavirus Aid, Relief, and Economic Security (CARES) Act authorized the Employee [...]
November 20, 2023
FinCEN has updated its Beneficial Ownership Information FAQs to include new questions regarding the reporting process, reporting companies, beneficial owners, company applicants, reporting requirements, initial reports, and reporting company exemptions. [...]
November 17, 2023
Regulators have announced the dollar threshold at which higher-priced mortgages become subject to special appraisal requirements will increase from $31,000 to $32,400 in 2024. The dollar threshold under which consumer [...]
November 14, 2023
The NMLS Annual Renewal Period began November 1st and ends on December 31st. According to federal regulations, mortgage loan originator registrants and institutions must renew their registrations annually. Once submitted [...]
November 9, 2023
Last week, the Treasury Department issued a final rule to hold financial institutions liable if they pay canceled Treasury checks without waiting to receive the return information that would let [...]
November 6, 2023
Central Daylight Savings Time has now ended! CST will be the abbreviation to use in our region to disclose the time zone when disclosing the date and time the interest [...]
October 31, 2023
The Consumer Financial Protection Bureau and the Department of Justice recently issued a joint statement regarding the potential civil rights implications of a creditor’s consideration of an individual’s immigration status [...]
October 10, 2023
The Financial Crimes Enforcement Network (FinCEN) has issued additional guidance materials for the Beneficial Ownership Information (BOI) reporting requirements, which are supposed to go into effect January 1, 2024. FinCEN [...]
October 5, 2023
Conducting a HMDA review before submitting your Loan Application Register (LAR) is imperative to ensure the accuracy and compliance of your Home Mortgage Disclosure Act (HMDA) data. Some institutions may [...]
September 27, 2023
FinCEN has published a small entity compliance guide to assist small businesses in complying with the beneficial ownership information reporting rule, which takes effect on Jan. 1, 2024. According to the [...]
September 22, 2023
The CFPB has announced the 2024 dollar amounts for the annual threshold adjustments for Regulation Z, Truth in Lending Act (TILA). For open-end consumer credit plans under TILA, the threshold [...]
September 20, 2023
FinCEN has issued an analysis of patterns and trends contained in Bank Secrecy Act reporting on suspected evasion of Russia-related export controls. The agency said the analyzed reports indicate almost [...]
September 18, 2023
FinCEN has issued an alert warning of a virtual currency investment scam called “pig butchering.” In the scams, bad actors use fake identities to build personal relationships with victims they [...]
September 15, 2023
All providers of ACH services, including participating depository institutions, third-party senders, and third-party service providers, are required to conduct an annual audit of the Nacha Operating Rules and Guidelines. This [...]
September 14, 2023
The CFPB has announced that the Filing Instructions Guide (FIG) for Home Mortgage Disclosure Act (HMDA) data collected in 2024 is now available. The 2024 FIG is a technical resource [...]
September 13, 2023
FDIC-supervised institutions are required to maintain up-to-date Equal Housing Lender posters in branches, as required by the Fair Housing Act. The agency recently amended some details of the posters, including [...]
August 29, 2023
The CFPB recently released an update to the Filing Instructions Guide (FIG) for Small Business Lending Data. The updates include: An administrative update changed Validation IDs from name codes to alphanumeric [...]
August 24, 2023
Last week, FinCEN and IRS Criminal Investigation issued a notice warning of a “concerning increase” in state and federal payroll tax evasion and workers’ compensation insurance fraud in the residential [...]
August 23, 2023
You may be aware of the increased attention around consumer payment fraud in the media. Due to recent high-profile bankruptcy cases involving cryptocurrency providers and exchanges, NACHA has become aware [...]
August 15, 2023
The Federal Financial Institutions Examination Council (FFIEC) has released updates to several sections of the Bank Secrecy Act / Anti-Money Laundering Examination Manual. These updates offer further transparency into the [...]
August 10, 2023
American Bankers Association (ABA) has launched an online directory to help banks resolve check fraud claims efficiently. This directory provides contact information for banks needing to file a check warranty [...]
August 8, 2023
If you have been in banking for any period of time and deal with the Bank Secrecy Act, you are aware that an independent test of the Bank’s BSA/AML/CFT Program [...]
August 3, 2023
On Monday, a federal judge in Texas issued an order blocking CFPB’s enforcement of the Section 1071 final rule while the Supreme Court deliberates a challenge to the constitutionality of [...]
July 28, 2023
Hopefully, by now, you have determined the number of Section 1071 covered transactions your Bank has made in the preceding two years to evaluate which Compliance Date Tier applies to [...]
July 14, 2023
The CFPB has published a page on its website of frequently asked questions related to the Section 1071 small business lending rule. The document covers two main topics: which institutions [...]
July 12, 2023
In April, the Treasury Department announced the 2023 De-Risking Strategy, mandated by the Anti-Money Laundering Act of 2020. This strategy shapes a safer, more transparent, and more accessible financial system [...]
July 10, 2023
It is important for your Bank to document the process taken to implement the small business lending collection and reporting requirements of Section 1071 of the Dodd-Frank Act. The CFPB [...]
July 6, 2023
A Compliance Officer faces challenges on a daily basis. It is not only the Compliance Officer’s responsibility to maintain an effective Compliance Management System (CMS), but it also requires the [...]
June 30, 2023
The Community Reinvestment Act (CRA) encourages banks to meet the credit needs of their local communities, including low- and moderate-income communities. Distressed or underserved nonmetropolitan middle-income geographies are census tracts [...]
June 28, 2023
As we are all aware, the FDIC originally issued supervisory guidance on multiple re-presentment NSF fees in August 2022, suggesting a two-year lookback and possible restitution. This month, the FDIC [...]
April 17, 2023
The FFIEC has released the 2023 version of A Guide to HMDA: Getting It Right! The Guide is a good resource for your HMDA team, including a summary of responsibilities [...]
April 11, 2023
NACHA has updated the sample Written Statement of Unauthorized Debt (WSUD) form to include language alerting consumers of the risks of making false claims of unauthorized ACH debits to their [...]
March 31, 2023
As promised, the CFPB issued the Section 1071 Final Rule yesterday, just before the March 31st deadline. The final rule implementing Section 1071 of the Dodd-Frank Act requires collecting and [...]
March 29, 2023
One of the principal functions of a bank’s Compliance Department is Change Management. Banks must continuously evolve and adapt to meet a variety of challenges. Potential changes could come from changes [...]
March 28, 2023
Effective January 1, 2024, certain entities will now be required to report their company’s Beneficial Ownership Information (BOI) directly to FinCEN. FinCEN has released new resources for filers to help with [...]
March 23, 2023
The CFPB has released the 2023 HMDA Transactional and Institutional Coverage Charts. The charts now reflect the updated closed-end mortgage loan threshold of 25. You can access the 2023 HMDA [...]
March 20, 2023
Each year, banks of all sizes must verify that their CRA Public file has been updated to include the below required items by April 1st. All written comments received from [...]
March 16, 2023
We have been notified of new social engineering and phishing attacks taking advantage of the recent bank failures. Attackers are impersonating vendors and sending false invoices and account change forms [...]
March 13, 2023
Central Daylight Savings Time has now started! CDT will be the abbreviation to use in our region to disclose the time zone when disclosing the date and time the interest [...]
March 7, 2023
The federal bank regulatory agencies have issued a joint statement addressing bank liquidity risks associated with certain funding sources from crypto-asset-related entities and effective practices to manage the risks. You [...]
March 3, 2023
FinCEN issued an Alert this week addressing the nationwide surge in check fraud schemes targeting the U.S. Mail. FinCEN is asking banks to be vigilant in identifying and reporting these [...]
February 21, 2023
Two changes to the ACH system that your bank should be aware of occur next month. First, the second phase of the Micro-Entry Rule will be effective on March 17, [...]
January 10, 2023
The CFPB has release their Regulatory and Reporting Overview Reference Chart for HMDA Data Collected in 2023. You can access the 2023 Reference Chart here. Also, remember the deadline for submitting [...]
January 6, 2023
Maintaining and collecting HMDA data can be challenging. As a HMDA Bank, you must accurately collect and report data because of the various critical purposes for which the data is [...]
January 4, 2023
Happy New Year! It’s that time again for annual threshold adjustments. The asset-size exemption threshold for institutions under Regulation C increased from $50 million to $54 million, effective January 1, [...]
December 27, 2022
The Federal Reserve and the FDIC have released the annual adjustment to the asset-size thresholds used to define ‘Small Bank’ and ‘Intermediate Small Bank’ under the CRA Regulations. As of [...]
December 22, 2022
The CFPB has updated the “What you should know about home equity lines of credit” brochure (HELOC Brochure). The updated HELOC Brochure, available in both English and Spanish, is meant [...]
December 8, 2022
The CFPB issued a blog post this week regarding the September 23rd 2022, court order vacating the 2020 Home Mortgage Disclosure Act (HMDA) Final Rule which brought the threshold for reporting [...]
November 4, 2022
The U.S. Equal Employment Opportunity Commission (EEOC) has updated their anti-discrimination poster that is required for covered employers to post. The updated poster titled “Know Your Rights: Workplace Discrimination is [...]
November 2, 2022
Hopefully, you are all aware of the recent court ruling overturning CFPB regulations that expanded the number of small-volume lenders deemed exempt from the Home Mortgage Disclosure Act (HMDA) reporting [...]
October 28, 2022
This week the CFPB released guidance on how to avoid charging illegal junk fees on deposit accounts. The guidance is specifically regarding surprise overdraft fees and surprise depositor fees. The [...]
October 27, 2022
When multiple properties (dwellings) are taken as collateral, HMDA reporting can be tricky. The Bank has a single line to enter data relating to multiple properties. There are data fields [...]
October 25, 2022
The NMLS Annual Renewal Period begins November 1st and ends on December 31st each year. According to federal regulations, mortgage loan originator registrants and institutions must renew their registrations annually. [...]
October 20, 2022
The Nacha Operating Rules and Guidelines require that all participating depository financial institutions, third-party senders, and third-party service providers that provide ACH services to the RDFI or ODFI, conduct an [...]
October 17, 2022
Last week regulators announced the dollar threshold at which higher-priced mortgages become subject to special appraisal requirements will increase from $28,500 to $31,000 in 2023. The dollar threshold under which [...]
October 10, 2022
The FFIEC has released an update to the October 2018 Cybersecurity Resource Guide for Financial Institutions. The updated resource guide now includes ransomware-specific resources to address the ongoing threat of ransomware incidents. You [...]
October 6, 2022
On September 16th, the Micro Entries Rule took effect which defines and standardizes practices and formatting of Micro-Entries, which are used by some ACH Originators as a method of account [...]
October 5, 2022
Last week, the Financial Crimes Enforcement Network issued a final rule establishing a beneficial ownership information reporting requirement. The rule will require most corporations, limited liability companies and other entities created [...]
October 4, 2022
On September 6, 2022, the CFPB released the 2023 Filing Instructions Guide and the Supplemental Guide for Quarterly Filers for 2023, which are available here. CCI suggests sharing this information with [...]
September 29, 2022
The Federal Deposit Insurance Corporation (FDIC) is making technical corrections to two regulations to reflect a reorganization and change in the name of its former Consumer Response Center. The new [...]
September 27, 2022
The Federal Reserve issued a Policy Statement encouraging the reporting of any information regarding any banking organization the Federal Reserve supervises or any director, officer, or employee of such banking [...]
September 13, 2022
Last month the Federal Reserve Board of Governors (Board) issued a Supervision and Regulation (SR) Letter on Engagement in Crypto-Asset-Related Activities by Federal Reserve Supervised Organizations. This letter provides guidance for all [...]
July 18, 2022
NACHA has announced that the relief from specific provisions of NACHA, provided in response to the COVID-19 pandemic, will expire on October 1st, 2022. The following breaks down the expiration of [...]
July 14, 2022
The 2022 list of distressed or underserved nonmetropolitan middle-income geographies was released by the federal banking agencies. These areas are eligible for CRA credits when banks provide loans for improvement [...]
July 8, 2022
Does your Bank have customers that own/operate their own ATM? The Financial Crimes Enforcement Network (FinCEN) recently issued a statement on how to apply a risk-based approach for conducting customer [...]
July 6, 2022
Re-presentment of Unpaid Transactions – Is this a heightened risk for your Bank? What is the problem? Banks commonly charge a non-sufficient funds (NSF) fee when a charge is presented [...]
June 22, 2022
A Bank’s Compliance Management System (CMS) includes board and management oversight, compliance program, and compliance audit. As a component of board and management oversight, management must be responsive to updates [...]
June 16, 2022
The Financial Crimes Enforcement Network (FinCEN) has issued an advisory to inform banks of the rising trend of elder financial exploitation (EFE). EFE involves the illegal or improper use of [...]
May 24, 2022
Is your Bank subject to HMDA reporting? If so, a revised version of “A Guide to HMDA Reporting: Getting It Right!” (Guide) was just issued. This Guide will assist your [...]
May 20, 2022
HUD has updated the Servicemembers Civil Relief Act (SCRA) Notice. The new notice (Form 92070) is available on HUD’s website and has a new expiration date of November 30, 2024. [...]
May 16, 2022
Last week, the banking agencies issued a set of revised and expanded interagency Q&As covering flood insurance compliance. The main points of the new guidance are related to the escrow [...]
April 8, 2022
CCI’s regular newsletters cover regulatory updates and reminders for bank compliance programs. While working alongside our clients, we often notice trends in the mistakes banks are making or specific items [...]
April 6, 2022
The 2022 edition of the ‘Guide to HMDA Reporting: Getting It Right!’ is available on the FFIEC website. You can access the guide here. CCI suggests sharing this information with the personnel [...]
March 28, 2022
As a reminder, a joint final rule was issued to establish computer-security incident notification requirements for banking organizations and their bank service providers. The effective dates are fast approaching. The [...]
March 11, 2022
Don’t forget! This Sunday, March 13th, is the start of daylight savings time. CDT will be the abbreviation to use in our region to disclose the time zone when disclosing the [...]
March 8, 2022
The Same Day ACH dollar limit will increase to $1 million per payment on March 18th. The Rule will apply to all Same Day ACH entries, including consumer payments and business [...]
March 2, 2022
There are two phases of changes that your bank will need to be aware of regarding Micro-Entries. The first phase is effective September 16, 2022, and the second phase will [...]
March 1, 2022
The CFPB has released a short factsheet on calculating prepaid interest on so-called ‘short-reset’ adjustable-rate mortgages and step-rate loans. The price-based General Qualified Mortgage definition has a special rule for calculating [...]
February 22, 2022
FinCEN has released a Fact Sheet on its Rapid Response Program (RRP). This collaborative partnership leverages FinCEN’s relationships with law enforcement, U.S. financial institutions, and foreign financial intelligence units to [...]
February 17, 2022
March 1, 2022, is the due date for the annual HMDA LAR submission of 2021 data for all banks regulated by the rule. Submissions of 2021 HMDA data will be [...]
February 10, 2022
The CFPB has released the Reportable HMDA Data: A Regulatory and Reporting Overview Reference Chart for HMDA Data Collected in 2022. The chart can be used as a reference tool for [...]
February 2, 2022
The CFPB has updated the Rural and Underserved Areas and Counties list, as well as updated the website tool, for areas determined to be “rural” or “underserved” and counties determined [...]
January 25, 2022
Last Friday, the FDIC approved a final rule that simplifies deposit insurance coverage for deposits held in connection with revocable and irrevocable trusts by merging these two deposit insurance categories [...]
January 5, 2022
Make sure to mark your calendars of upcoming important dates. January: Effective on the 1st – Reg. Z exemption threshold increase – CRA threshold increased for small and intermediate small banks – Threshold [...]
December 29, 2021
The CFPB has released the annual asset size exemption thresholds for depository institutions under Regulation C. Banks, savings associations, and credit unions with assets of $50 million or less as of [...]
December 20, 2021
The federal regulators have announced the annual adjustment to the asset-size thresholds for small and intermediate banks and savings associations under the Community Reinvestment Act taking effect on January 1, [...]
December 14, 2021
The CFPB has updated the Electronic Fund Transfers (EFTs) Frequently Asked Questions (FAQs). Multiple Questions and Answers have been updated as of 12/13/21 (updated date is listed next to each [...]
December 3, 2021
Effective January 1st, 2022, the dollar threshold for exempting loans from the special appraisal requirements under the Truth in Lending Act Higher Priced Mortgage Loan Appraisal Rule will increase from [...]
November 30, 2021
A final rule has been issued that requires a bank to notify its primary federal regulator of any “computer-security incident” that rises to the level of a “notification incident,” as [...]
November 24, 2021
Last week FinCEN issued a notice to raise awareness of an upward trend in environmental crimes and associated illicit financial activity. The notice includes SAR filing instructions and highlights the likelihood [...]
November 22, 2021
Effective January 1, 2022, the threshold for reporting HMDA data on open-end lines of credit will adjust from 500 to 200 open-end lines of credit. This means if your bank [...]
November 17, 2021
As of November 10, 2021, the CFPB will no longer apply the temporary supervisory and enforcement flexibility announced in the April 3, 2020 “Joint Statement on Supervisory and Enforcement Practices [...]
November 15, 2021
Effective January 20, 2022, all MLA database users will be required to log into their accounts at least once every 35 days to maintain active-account status. After 35 days of [...]
November 15, 2021
The annual renewal period for Mortgage Loan Originator(s) on the Nationwide Mortgage Licensing System (NMLS), as required by the SAFE Act, is coming to a close on December 31st. CCI [...]
November 12, 2021
FinCEN has updated a previously released Advisory on Ransomware and the Use of the Financial System to Facilitate Ransom Payments due to an increase of ransomware attacks in recent months. [...]
November 10, 2021
Last week, the Consumer Financial Protection Bureau (CFPB) issued an advisory opinion applying to all consumer reporting agencies. This advisory opinion highlights that a consumer reporting agency that uses inadequate [...]
November 3, 2021
The CFPB is required to annually calculate the dollar amounts for several provisions in Regulation Z. Effective January 1, 2022, the dollar amounts for provisions implementing TILA and amendments to [...]
October 27, 2021
Last week an interagency statement was released addressing the risks posed to banks from the discontinuation of LIBOR. The statement advises banks to continue to transition to other reference rates [...]
October 27, 2021
Last week an interagency statement was released addressing the risks posed to banks from the discontinuation of LIBOR. The statement advises banks to continue to transition to other reference rates [...]
September 17, 2021
Yesterday FinCEN released a notice to call attention to online child sexual exploitation (OCSE) in response to an increase in OCSE crimes. The notice highlights financial trends to be aware of and provides specific instructions for filing suspicious activity reports (SARs). [...]
September 16, 2021
The CFPB has released their Filing Instructions Guide (FIG) for Home Mortgage Disclosure Act (HMDA) data collected in 2022. The FIG will assist with filing HMDA data in 2023 that was collected in 2022. A Supplemental Guide for [...]
September 10, 2021
In 2020, the CFPB finalized the Debt Collection Final Rules revising Regulation F, which implements the Fair Debt Collection Practices Act, effective November 30, 2021. On April 7, 2021, the [...]
September 3, 2021
Effective September 17, 2021, the Meaningful Modernization Rule has five amendments to improve and simplify the ACH user experience for authorization and initiation of ACH payments; reduce barriers to the [...]
August 21, 2021
Yesterday, an updated version of the Mortgage Servicing Small Entity Compliance Guide was released. The updated guide includes an overview of the 2020 Mortgage Servicing COVID-19 Interim Final Rule and the 2021 Mortgage Servicing COVID-19 Final Rule and identifies [...]
July 27, 2021
On August 1st, Nacha will implement the second phase of the ACH Contact Registry Rulemaking that effectively enforces the Rule. Previously, only Originating Depository Institutions needed to register contact information. [...]
July 8, 2021
The CFPB has released a Spanish translation of certain model clauses available for use in early intervention written notices issued under the Mortgage Servicing Rules. Banks are encouraged to be responsive to borrower needs by ascertaining borrower language preferences and providing translated [...]
July 7, 2021
Last week, FinCEN released the first government-wide priorities for anti-money laundering and countering the financing of terrorism, identifying and describing the most significant AML/CFT threats currently facing the United States. The Priorities include corruption, cybercrime, domestic and international [...]
June 30, 2021
The FFIEC has released their Distressed and Underserved Tracts list for 2021. You can access the list here. CCI suggests forwarding this information to your Bank’s CRA Officer. We are happy to help with any questions regarding [...]
June 29, 2021
Monday, the CFPB issued the 2021 Mortgage Servicing COVID-19 Final Rule. The Rule amends certain Mortgage Servicing early intervention and loss mitigation requirements under Regulation X. The Rule establishes procedural safeguards for mortgage servicers that assist borrowers with foreclosure alternatives, such as [...]
June 22, 2021
The IRS has announced Advance Child Tax Credit (ACTC) payments will be sent via Direct Deposit with an effective date of July 15, 2021. Recurring monthly payments will continue through [...]
June 17, 2021
Effective June 30, 2021, the new rule limits the length of time in which an RDFI will be permitted to make a claim against the ODFI’s authorization warranty. For an entry [...]
June 15, 2021
The Reversal Rule changes become effective June 30, 2021. The Rule explicitly addresses improper uses of reversals. It expands the permissible reasons for a reversal to include a “wrong date” error – 1) the [...]
June 8, 2021
Last Friday, the CFPB issued Electronic Fund Transfers (EFT) Frequently Asked Questions (FAQs). The FAQs address the unauthorized transfer and error resolution provisions under the Electronic Fund Transfer Act and [...]
June 7, 2021
The CFPB has released a set of FAQs that discuss topics regarding escrow accounts under Regulation X. The FAQs provide a general overview of the escrow account provisions in Regulation [...]
June 4, 2021
Yesterday, the Federal Reserve issued a final rule amending Regulation D, which addresses reserve requirements of depository institutions. The final rule eliminates references to an “interest on required reserves” rate [...]
April 29, 2021
Tuesday, the CFPB issued a final rule to delay until October 2, 2022, the mandatory compliance date for the General QM Final Rule. The CFPB also issued an executive summary and an unofficial redline of the rule and has updated other ATR/QM [...]
April 21, 2021
Monday, the CFPB used an interim final rule (IFR) to address certain debt collector conduct associated with the COVID-19 pandemic temporary eviction moratorium issued by the CDC. Effective May 3rd, the IFR requires debt collectors, as defined in the FDCPA, [...]
April 16, 2021
This morning the CFPB released an updated version of the Debt Collection Small Entity Compliance Guide to include a section on the December 2020 Final Rule. You can find the updated Compliance [...]
April 7, 2021
Last week the CFPB rescinded seven policy statements that provided banks flexibilities when serving customers during the Covid-19 pandemic. As of April 1, 2021, the following policy statements have been rescinded: A statement announcing that the CFPB would take [...]
April 7, 2021
The Federal Reserve recently issued a statement announcing the adoption of a new final rule that outlines and confirms the use of supervisory guidance for regulated institutions. The final rule was based [...]
April 5, 2021
The 2021 edition of ‘Guide to HMDA Reporting: Getting It Right!’ is now available on the FFIEC website. You can access the guide here. A Guide to HMDA Reporting: Getting It Right! (ffiec.gov) Please [...]
April 2, 2021
Earlier this week, following the previous announcement from the IRS extending the federal income tax filing due date for individuals for the 2020 tax year from April 15, 2021, to [...]
March 30, 2021
The SBA has released a second procedural notice with updated instructions on how to clear hold codes and compliance check error messages when submitting first and second-draw PPP loans. The [...]
March 26, 2021
FinCEN has issued a Notice informing about ongoing efforts related to the Anti-Money Laundering Act of 2020 requirements pertaining to antiquities and art trades. The Notice provides information about illicit [...]
March 15, 2021
The third round of economic impact payments (EIPs) will begin reaching Americans over the next week, and direct deposit payments began to arrive over the past weekend. The IRS has [...]
March 11, 2021
The CFPB has issued an interpretive rule clarifying that the prohibition against sex discrimination under the Equal Credit Opportunity Act (ECOA) and Regulation B includes sexual orientation discrimination and gender [...]
March 11, 2021
The CFPB has issued an interpretive rule clarifying that the prohibition against sex discrimination under the Equal Credit Opportunity Act (ECOA) and Regulation B includes sexual orientation discrimination and gender [...]
March 10, 2021
The banking agencies have updated a list of frequently asked questions related to the Community Reinvestment Act and COVID-19. There are five new FAQ’s that clarify: CRA regulatory criteria for the [...]
February 9, 2021
The SBA has released a Notice to update Procedural Notice 5000-20036, which informs Paycheck Protection Program (PPP) Lenders of the reporting process through which PPP Lenders will report on PPP loans [...]
February 3, 2021
Yesterday the Financial Crimes Enforcement Network released an advisory to warn banks of COVID-19 related fraud, specifically involving the health care industry. The advisory contains descriptions of fraud involving health care benefit programs and health insurance, associated financial [...]
January 21, 2021
Earlier this week, FinCEN released responses to Frequently Asked Questions regarding Suspicious Activity Reporting and other Anti-Money Laundering Requirements. The FAQs are meant to help clarify regulatory compliance obligations, allowing banks to focus resources on the BSA activities that [...]
January 20, 2021
Yesterday, the CFPB issued a final rule that adds a new exemption from the Regulation Z HPML requirement for establishing an escrow account for certain higher-priced mortgage loans. The final rule exempts secured loans made by insured depository or credit union institutions when the institution has met [...]
January 12, 2021
Listed below are notable dates for your ACH compliance program this year. More information will be released on each closer to their effective dates. March 19, 2021 – Effective date of the Rule to Expand [...]
December 30, 2020
Families First Coronavirus Response Act requires employers with fewer than 500 employees to provide paid sick leave and paid FMLA leave for employees with qualifying reasons. The FFCRA also permits employers [...]
December 30, 2020
Last week, the Bureau issued an advisory opinion on special purpose credit programs. The advisory opinion clarifies the content that a for-profit organization must include in a written plan that establishes and administers [...]
December 29, 2020
Yesterday, FinCEN issued a Notice for banks to stay alert for potential fraud, ransomware attacks, or similar criminal activity related to COVID-19 vaccines and their distribution. The Notice provides specific information on filing Suspicious [...]
December 28, 2020
Last week, the CFPB amended the requirements of Regulation C (Home Mortgage Disclosure Act) to reflect the asset-size exemption threshold for banks. The exemption threshold is adjusted to $48 million from $47 million. Therefore, banks with [...]
December 23, 2020
Earlier this month, the CFPB issued two final rulings amending the Ability to Repay/Qualified MortgageRule (ATR/QM). The final rules are: General QM Final Rule: Replaces the existing 43% debt-to-income ratio limit in the General QM definition with price-based thresholds, among other [...]
December 21, 2020
Effective January 1, 2021, the Enforcement Rule is intended to deter and prevent activity that can cause significant harm to banks and the ACH Network. The Enforcement Rule: Defines an egregious violation as a willful or [...]
December 18, 2020
Yesterday the agencies released the annual Community Reinvestment Act (CRA) asset-size thresholds for 2021. Banks are evaluated under different CRA examination procedures depending on their asset-size classification. The below changes to the definitions of small and intermediate small institutions for CRA examinations are [...]
December 17, 2020
This is a reminder to check your loan software to verify all dollar amounts of the various Regulation Z (Truth in Lending Act, TILA) thresholds are updated for 2021, as of January 1, 2021. 2021 TILA Threshold Checklist: 1.Credit Card [...]
December 14, 2020
Last week the Financial Crimes Enforcement Network (FinCEN) addressed the importance of information sharing in identifying, reporting, and preventing financial crimes such as money laundering and terrorist financing. Important clarification on FinCEN’s information sharing under [...]
December 7, 2020
Last week, the CFPB released its Advisory Opinion program. The Advisory Opinion program will provide written guidance to assist banks to better understand their legal and regulatory obligations through advisory [...]
December 2, 2020
Developed to help banks assess their efforts to mitigate risks associated with ransomware and identify gaps for increasing security, the Ransomware Self-Assessment Tool (R-SAT) has now been updated to better [...]
November 30, 2020
Last week, the CFPB released an update to the Filing Instructions Guide (FIG) for HMDA data collected in 2021 and reported in 2022. Updates include the reclassification of edits Q656 [...]
November 23, 2020
Last week, the CFPB released three Threshold Adjustments effective January 1, 2021. 1. Threshold for exempting loans from special appraisal requirements under the TILA Higher Priced Mortgage Loan Appraisal rule. [...]
November 2, 2020
Last Friday, the CFPB released a portion of the Fair Debt Collection Practices Act final rule. As the rule pertains to third-party debt collection, it does not generally apply to [...]
October 27, 2020
Last week, the CFPB issued the Patch Extension Final Rule amending the Ability-to-Repay/Qualified Mortgage Rule. The Final Rule extends the sunset date for the Temporary GSE QM category. The Temporary [...]
October 14, 2020
Yesterday, the Financial Crimes Enforcement Network (FinCEN) issued an advisory alerting financial institutions of unemployment insurance (UI) fraud detected during the COVID-19 pandemic. The below are representative types of illicit [...]
October 13, 2020
Last week, the Bureau released a set of Frequently Asked Questions (FAQs) related to the Real Estate Settlement Procedures Act (RESPA) and Regulation X. The FAQs cover the provisions in [...]
September 29, 2020
In response to banks requesting clarification regarding Customer Due Diligence (CDD) for Politically Exposed Persons (PEPs), the FRB, FDIC, FinCEN, NCUA, and the OCC issued a joint statement clarifying the [...]
August 24, 2020
Late last week, the CFPB released the Filing Instruction Guide (FIG) for HMDA data collected during 2021 to be reported in 2022. In addition, they also released a Supplemental Guide [...]
August 12, 2020
Yesterday, the CFPB released a document with Frequently Asked Questions (FAQs) pertaining to the Small Dollar Lending Rule. The FAQs discuss Covered Loans, Payment Transfers, and Payment Notices. You can [...]
August 10, 2020
Last week, the FFIEC issued a statement discussing risk management and consumer protection principles banks should consider while working with borrowers as the initial coronavirus-related loan accommodations come to an [...]
August 7, 2020
Early this week, FinCEN issued three new FAQs related to customer due diligence requirements. The new FAQs address customer information risk-based procedures, customer risk profiles, and ongoing monitoring of the [...]
August 5, 2020
The FFIEC has updated its Census and Demographic Data information available for use with HMDA and CRA. Census data are available in the following formats: • FFIEC Online Census Data [...]
August 4, 2020
Last week, the CFPB released two HMDA FAQs. 1. Are financial institutions required to report the credit score, DTI, and CLTV relied on in making a credit decision when such [...]
July 31, 2020
Yesterday, FinCEN released an advisory on Cybercrime and Cyber-Enabled Crime exploiting the COVID 19 Pandemic. The advisory includes descriptions of COVID-19 related malicious cyber activity and scams and their associated [...]
July 22, 2020
NACHA has expanded its existing security framework for the ACH Network to include requiring parties with large volumes to protect account numbers used in the ACH payment. The account number [...]
July 15, 2020
Last week, NACHA released guidance regarding the March 20, 2020 change increasing the dollar limit on large-dollar Same-Day ACH Entries from $25,000 to $100,000 per entry. This change limits single [...]
July 8, 2020
Yesterday, the CFPB issued a final rule to amend their 2017 Payday Lending Rule governing payday, vehicle title, and certain high-cost installment loans. Specifically, the Bureau is revoking: 1. that [...]
June 26, 2020
Earlier this week, the Agencies released the 2020 list of distressed or underserved nonmetropolitan middle-income geographies. These areas are eligible to receive Community Reinvestment Act (CRA) consideration under the community [...]
June 20, 2020
NACHA has created an industry resource, the ACH Contact Registry, to help connect financial institutions regarding ACH operations, exceptions, and risk management. To make sure all financial institutions participate, NACHA [...]
June 17, 2020
Yesterday, the CFPB released FAQs on bank responsibilities under the CARES Act and FCRA when they furnish information to consumer reporting agencies related to consumers impacted by the crisis. You [...]
June 10, 2020
Yesterday the CFPB released helpful resources related to the TILA-RESPA Integrated Disclosure (TRID) Rule. The newly available resources include a Factsheet detailing how to disclose title insurance on the Loan [...]
June 3, 2020
Previously, any ‘person’ entering or exiting the United States physically transporting $10,000 or more in currency or other monetary instruments at one time was required to file the Currency and [...]
CCI Updatesmaly-cc-admin2026-04-27T09:32:10-05:00