CDD & Politically Exposed Persons

December 9, 2020 - 4 min read

The agencies (FinCEN, FDIC, FRB, OCC, and NCUA) (collectively, the Agencies) issued a joint Statement on BSA Due Diligence Requirements for Customers Who May Be Considered Politically Exposed Persons (PEPs) on August 21, 2020 (the PEP Statement). The PEP Statement addresses questions raised by banks on how to apply a risk-based approach to PEPS consistent with…

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Quarterly HMDA Reporting

June 11, 2020 - 1 min read

On March 26, 2020, the CFPB issued a statement to inform its supervised financial institutions that it does not intend to cite in an examination or initiate an enforcement action for failure to report the quarterly HMDA data for those institutions subject to the new 2018 HMDA quarterly reporting requirements. Financial institutions that report for…

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