DOMESTIC TERRORISM – THE NEW THREAT Once when one thought of “terrorism,” it was foreign terrorism that came to mind. And what would a community bank have to do with that? But terrorism has moved closer to home. There has …
CFPB ISSUES ADVISORY OPINION ON SPECIAL PURPOSE CREDIT PROGRAMS Under the Equal Credit Opportunity Act (ECOA) banking institutions are allowed to extend “special purpose credit” when the Bank intends to meet special social needs. The plan must be written, identify …
CFPB ISSUES ADVISORY OPINION ON SPECIAL PURPOSE CREDIT PROGRAMS Evelyn I. Dehmey
ARE YOU THE “TRUE LENDER”? The court ruled in the “Madden” case that the assignee of a loan made by a national bank or federal savings association may charge the same interest rate that the bank or savings association is …
On October 30, 2020 the CFPB announced a final version of the Fair Debt Collection Practices Act. Although the rule is generally applicable to third-party debt collection practices, it has an indirect effect on financial institutions. First, at a pre-described …
Consumer financial services has been a hot topic in California and was recently solidified with the passage of AB-1864. This bill renames the current “Department of Business Oversight” as the “Department of Financial Protection and Innovation” (DFPI). The former authority …
Time to Dust Off and Update Your BSA and OFAC Risk Assessment! As children starting the arduous process of composing their wish list for Santa, many financial institutions are making and preparing and receiving lists for their own end-of-year tradition …
Julie J. Mixtacki Time to Dust Off and Update Your BSA and OFAC Risk Assessment
FinCEN Releases Further Guidance for Banking Hemp-Related Business Customers While fielding the daily news and guidance about COVID-related fraud and considerations, it may have been easy to miss FinCEN’s update regarding expectations for performing due diligence for hemp-related business customers. …
FinCEN Releases Further Guidance for Banking Hemp-Related Business Customers Julie J. Mixtacki
On June 24, 2020 the FFIEC announced the availability of 2019 HMDA Disclosures. At the same time, they shared an analysis of the aggregate data submitted, comparing 2018 data with 2019 data. This helps us to understand how financial institutions …
How might HMDA Thresholds Affect Your Institution? On April 16, the CFPB announced its final rule on the thresholds for reporting closed-end and open-end loans for HMDA. The threshold for closed-end mortgage loans increased from 25 to 100 loans effective …
Evelyn I. Dehmey How might HMDA Thresholds Affect Your Institution
Are You Aware of NACHA’s New Registry Requirement? NACHA is implementing a new registry, the ACH Contact Registry, for all financial institutions involved in ACH operations. The purpose of the new registry is to allow financial institutions to interact with …