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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 This latest FAQ is an update to the previous and now-rescinded version,...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 organizations 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...
02/2020
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 practices 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...
11/2019
OCC Fines Financial Institution $30 Million for OREO Violations On October 11, 2019, the Office of the Comptroller of the Currency (OCC) assessed a $30 million civil money penalty against a large, multinational bank under a consent order for violations related to the holding period of other real estate owned (OREO). The OCC found that the bank engaged in repeated violations of the statutory holding period for OREO and failed to meet its commitment to implement corrective actions, resulting in additional violations. OREO refers to bank-owned real estate acquired in satisfaction of previously...
10/2019
CFPB Issues Innovation Policies The Consumer Financial Protection Bureau (CFPB) was established by the Dodd-Frank Act (Dodd-Frank) for the primary purpose of implementing and enforcing federal consumer financial law. However, the Dodd-Frank Act also authorizes the CFPB to use its powers to accomplish other objectives.  One of those objectives is to ensure that markets for consumer financial products and services operate transparently to facilitate access and innovation.  Recently, the CFPB reminded the industry of its commitment to innovation when it updated two previously issued policy...
09/2019
Federal Reserve to Develop Real-Time Payment and Settlement Service to Support Faster Payments On August 5, 2019, the Federal Reserve Board (FRB) announced plans to develop a new interbank round-the-clock and real-time gross settlement service called the FedNow Service to support faster payments. With integrated clearing functionality, FedNow will involve the settlement of interbank obligations through entries in banks’ master accounts at the Federal Reserve Banks. The planned service will support domestic transfers up to $25,000 with processing times expected to be seconds. Participation in...
08/2019
Disparate Impact Risk of AI Use in Underwriting On May 9, 2019, Maxine Waters (D-CA), chairwoman of the House Committee on Financial Services, announced the creation of a Task Force on Artificial Intelligence (Task Force). The Task Force, chaired by Congressman Bill Foster (D-IL), is responsible for informing Congress on the financial services industry’s use of artificial intelligence (“AI”) and its impact on consumers, investors, and small businesses. The Task Force held its first hearing, titled “Perspectives on Artificial Intelligence: Where We Are and the Next Frontier in Financial...
07/2019
Your monthly compliance news roundup SEC Adopts Regulation Best Interest to Enhance Protections for Retail Investors Recent OFAC Amendments Include New Obligations FDIC Releases Supervisory Highlights Outlining Consumer Compliance Issues CFPB Releases Spring 2019 Rulemaking Agenda SEC Adopts Regulation Best Interest to Enhance Protections for Retail Investors On June 5, 2019, the Securities and Exchange Commission (SEC) adopted rules designed to enhance the quality and transparency of retail investors’ relationships with investment advisors and broker-dealers. Of specific...