Protiviti Compliance Insights

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10/2020
Your monthly compliance news roundup Protecting Institutions Against PPP Fraud On September 10, 2020, Brian Rabbitt, acting assistant attorney general in the U.S. Department of Justice (DOJ), provided a status update on the department’s efforts to combat Paycheck Protection Programme (PPP) fraud. According to Rabbitt, the DOJ has filed charges against 57 individuals for fraudulently obtaining or attempting to obtain approximately $175 million in PPP funds for personal gain. A linchpin of the Coronavirus Aid, Relief and Economic Security (CARES) Act, enacted on March 27, 2020, the PPP was...
09/2020
Your monthly compliance news roundup Agencies Update Guidance on BSA/AML Compliance Programme Expectations On August 13, 2020, the Federal Reserve Board, the Federal Deposit Insurance Corporation (FDIC), the National Credit Union Administration (NCUA) and the Office of the Comptroller of the Currency (OCC) released a joint statement that explains the enforcement of certain Bank Secrecy Act (BSA)/anti-money laundering (AML) requirements. The statement identifies instances in which an agency may issue a mandatory cease and desist order to address compliance failures with certain requirements...
08/2020
Your monthly compliance news roundup CFPB Issues Interim Final Rule to Amend Regulation X Offering Relief to Consumers  In light of the ongoing COVID-19 pandemic, the Consumer Financial Protection Bureau (CFPB) has issued an interim rule permitting mortgage servicers to offer new loss mitigation options following the evaluation of an incomplete loss mitigation application. In March 2020, Congress passed the CARES Act, which required that borrowers with federally backed mortgage loans have access to payment forbearance plans. The new interim rule, which became effective July 1, 2020, creates...
07/2020
In your monthly compliance news roundup, you will read about: Implications of Class Action Suit Alleging Misleading Autopay Options Recapping Regulatory Responses to COVID-19 DOJ Updates Guidance on Evaluating Corporate Compliance Programmes Regulators Aim to Provide Financial Institutions Clear Guidance and Improve Compliance Implications of Class Action Suit Alleging Misleading Autopay Options A complaint was filed on behalf of a financial institution customer in a New Jersey federal court on June 3, 2020, alleging that a large national bank intentionally deceived customers into accruing...
06/2020
Your monthly compliance news roundup FinCEN: BSA Reporting Obligations Remain Crucial During COVID-19 as Fraud Trends Rise The first case of the novel coronavirus (COVID-19) in the United States was confirmed on January 20, 2020, two months after the first known cases are believed to have originated in China. While the world turned its attention to the virus and finding effective treatment, a hidden threat emerged: fraud. Law enforcement detected an increase in fraud schemes exploiting the COVID-19 pandemic for illicit financial gain, prompting the Financial Crimes Enforcement Network (FinCEN...
05/2020
Your monthly compliance news roundup BSA/AML Examination Manual Updates from FFIEC On April 15, 2020, the Federal Financial Institutions Examination Council (FFIEC) released updates to the Bank Secrecy Act/Anti-Money Laundering (BSA/AML) examination manual. The manual is used to evaluate an institution’s compliance with the Bank Secrecy Act and anti-money laundering requirements. This is the first and a much-anticipated revision since 2014. Although the updates do not establish any new requirements, they offer valuable insight and transparency into the examination process and highlight the...
04/2020
Your monthly compliance news roundup OCC Reinforces Third-Party Risk Management Expectations Regulatory expectations related to third-party relationships have evolved considerably since 2013, when the Federal Reserve Board and Office of the Comptroller of the Currency (OCC) issued prescriptive guidances SR 13-19 and OCC 2013-29, respectively. To account for this evolution, the OCC published OCC Bulletin 2020-10, “Third-Party Relationships: Frequently Asked Questions to Supplement OCC Bulletin 2013-29,” on March 5, 2020. This latest FAQ is an update to the previous and now-rescinded version,...
03/2020
Protiviti is committed to remaining the source for insights on the latest news in compliance you’ve come to expect. While the articles in this issue were developed prior to the escalation of events regarding COVID-19, we know they may still be impacting your organisations amid the current circumstances. For all dedicated COVID-19 coverage, visit Protiviti.com/COVID-19 and seek out our upcoming April issue for analysis of the impacts on specific areas of regulatory compliance. Using AI to Reduce Bias in Financial Services On February 12, 2020, the House Financial Services Committee’s Task...
03/2020
Consumer Compliance Implications of LIBOR Replacement Much has been written about the issue of LIBOR replacement and the potential risks that could arise absent prudent planning by impacted stakeholders. Although the financial impact has been widely discussed, consumer-compliance concerns appear to have garnered little attention. That is not to say there is an absence of risk. LIBOR, or the London Interbank Offer Rate, is one of two interest rate benchmarks commonly used for repricing adjustable rate mortgage (ARM) loans, with the other being the Constant Maturity Treasury (CMT) rate. LIBOR...
01/2020
Prediction: Key Compliance Risks for 2020 (and Beyond) It is a new year, and some would say a new decade. But while a decade changes with the stroke of the clock, social and technological changes are typically years in the making, marching slowly forward as if preordained. Changes in business practises follow closely behind, as the least adaptable ones fade from sight and the entrepreneurial ones emerge or redefine themselves. The legislative and regulatory communities endeavor to keep pace, fueled or restrained by the current political climate, but always trying to ensure consumer protection...