Banking regulators are temporarily reducing their examination schedules. At first glance, this reduction may seem to indicate that it is appropriate to ditch your compliance hat until the current quarantine period is behind us. Hold on to that hat though – while the examination schedule is delayed, regulatory requirements continue, and this new environment [...]
On April 15th, federal and state financial institution regulators, through the Federal Financial Institutions Examination Council (FFIEC), released several updates to the Bank Secrecy Act/Anti-Money Laundering (BSA/AML) examination manual. The manual is used to evaluate compliance with the Bank Secrecy Act and anti-money laundering requirements. Revisions were made by the Federal Reserve Board, Federal Deposit [...]
On March 27, President Trump signed the Coronavirus Aid, Relief, and Economic Security Act (CARES Act) to provide emergency assistance for those affected by the coronavirus pandemic. As part of the CARES Act, the U.S. Small Business Administration (SBA) received funding and authority to assist small businesses nationwide that have been adversely impacted by the COVID-19 emergency. In its Interim Final Rule (the Rule), the SBA sets out [...]
On April 1, 2020, the Consumer Financial Protection Bureau (CFPB) released the Modified Loan Application Registers (LARs) reflecting 2019 mortgage lending activity reported under the Home Mortgage Disclosure Act (HMDA). These reports represent the second release of HMDA data under the new rule implemented in 2015. Starting in 2018, under the 2015 HMDA Rule, financial [...]
On April 6, 2020, a white paper on the effects of the coronavirus pandemic was published publicly and addressed to the current director of the Consumer Financial Protection Bureau (CFPB, the Bureau), Kathleen Kraninger. This white paper – authored by Richard Cordray (former CFPB director), Diane Thompson (former CFPB deputy assistant director of regulations) and [...]
