FFIEC Issues Guidance on Authentication & Access to Financial Institution Services & Systems

November 16, 2021 - 9 min read

On August 11, 2021, the Federal Financial Institutions Examination Council (FFIEC) on behalf of its members1 issued guidance titled, Authentication and Access to Financial Institution Services and Systems (the Guidance) to provide financial institutions with examples of effective risk management principles and practices for access and authentication. These principles and practices address business and consumer…

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FDIC Issues Community Bank Guide on Conducting Due Diligence on Fintech Companies

November 12, 2021 - 2 min read

On August 27, 2021, the Federal Deposit Insurance Corporation (FDIC) published FIL-59-2021, Conducting Due Diligence on Financial Technology Companies: A Guide for Community Banks. Some banks may be exploring financial technology (fintech) companies in an effort to provide access to new or innovative technologies, as fintech can provide community banks with many benefits, such as…

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CFPB Issues Technical Specs for Credit Card Agreements & Data Submission

November 4, 2021 - 2 min read

On August 20, 2021 the Consumer Financial Protection Bureau (CFPB) issued new technical specifications for complying with credit card agreement and data submission requirements under TILA and the CARD Act (Regulation Z). Credit card issuers will use the CFPB’s “Collect” website to submit the following data to the CFPB, starting with listed submission dates and…

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CFPB Issues Consumer Complaint Patterns by Demographics of Census Tracts Report

November 2, 2021 - 3 min read

On September 23, 2021, the CFPB issued its first in-depth report analyzing complaint submission patterns by U.S. Census tract. The report, “Consumer complaints throughout the credit life cycle, by demographic characteristics,” finds that the complaints from wealthier communities and communities with higher percentages of white, non-Hispanic residents were more frequently about loan origination and performing…

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Daylight Savings Time Ending Means Disclosure Review Time!

December 2, 2020 - 2 min read

Since the Credit Card Accountability Responsibility and Disclosure (CARD) Act was passed back in 2009, the time change has impacted various consumer disclosures financial institutions must provide, such as conforming payment notices for credit cards and consumer mortgage loans, as well as the Loan Estimate disclosure under TRID. Conforming payment notices should be reviewed to…

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Statement by FinCEN Regarding Unlawfully Disclosed Suspicious Activity Reports

November 30, 2020 - 3 min read

On September 1, 2020, the Financial Crimes Enforcement Network (FinCEN) issued a statement regarding unlawfully disclosed Suspicious Activity Reports (SARs). FinCEN stated it is aware that various media outlets intended to publish a series of articles based on unlawfully disclosed SARs, as well as other sensitive government documents, from several years ago. As FinCEN has…

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Protecting Tenants Against Foreclosure

May 25, 2020 - 1 min read

Institutions are reminded that notwithstanding any executive orders regarding foreclosures or evictions regarding shorter time periods, if an institution becomes the successor in interest of a dwelling or residential real property in which a bona fide tenant resides, such tenant must be provided with a notice to vacate at least 90-days prior to the effective…

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Risk Management Guidance for Higher-Loan-to-Value Lending Activities in Communities Targeted for Revitalization

September 30, 2019 - 5 min read

On June 19, 2019, the Office of the Comptroller of the Currency (OCC) issued OCC Bulletin 2019-28 Risk Management Guidance for Higher-Loan-to-Value Lending Activities in Communities Targeted for Revitalization (the 2019 Bulletin) and rescinded its prior bulletin of the same title, OCC Bulletin 2017-28 (issued August 21, 2017) (the 2017 Bulletin). The purpose of the…

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TRID Construction FAQs

September 17, 2019 - 3 min read

On May 31, 2019, the CFPB released two new frequently asked questions (FAQs) to address the application of the TILA-RESPA Integrated Disclosure (TRID) rules to consumer construction loans. FAQ #1: Are construction-only loans or construction-permanent loans covered by the TRID Rule? Yes. Generally, a loan, including a construction-only and construction-permanent loan, is covered under TRID if…

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Community Reinvestment Act

September 11, 2019 - 3 min read

 The Federal Deposit Insurance Corporation (FDIC) recently released their Community Reinvestment Act (CRA) exam schedule for the 3rd quarter of 2019. Whether your institution is on the exam schedule or not, it is important to keep up-to-date regarding knowledge of your assessment area. Below are useful resources for information regarding state, county, census tracts, and…

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