Special Release

On April 10, 2018, the FFIEC issued a joint statement regarding Cyber Insurance and its role in Risk Management programs. With Cybersecurity events becoming commonplace, do you have the proper insurance to protect the bank and its assets? Although Cyber Insurance may be a part of the Risk Mitigation program, it is not the final […]

On April 3, 2018, FinCEN issued a frequently asked questions (FAQ) document, FIN‐2018‐G001, discussing the Beneficial Ownership Rules which go into effect on May 11, 2018. The FAQ addresses the following topics, among others: Beneficial Ownership Threshold Interaction of the beneficial ownership threshold with other AML program obligations Collection of beneficial ownership information for direct

Thanks to an eagle‐eyed client for sharing with us a best‐kept secret that HUD released an updated SCRA Notice. As you know, the old form expired in December 2017. From what we can tell, the only changes to the notice are dates and the reference to 50 USC 3901‐4403, which was changed from the former

On March 13, 2018, the CFPB issued an updated Small Entity Compliance Guide (SEG) to incorporate recent 2018 changes to the Regulation E Prepaid Card rules which take effect on April 1, 2019. The Bureau released guidance for completing the short‐form disclosure for prepaid accounts, which includes not only a line‐by‐line how‐to but specifics on

On February 21, 2018, the FFIEC released a revised HMDA: Getting It Right guide (GIR) for Regulation C changes which took effect on January 1, 2018. The GIR is in the same format as previous guides and it includes the regulation, appendices and commentary in 12 CFR §1002 plus the CFPB tools. The GIR is

On Thursday, February 1, 2018, the Consumer Financial Protection Bureau (CFPB) released a statement indicating that the 2018 HMDA LAR Formatting Tool is now available. The tool, which is available here, is for use by those institutions not currently using an automated system for processing their HMDA LAR. Under the new HMDA reporting rules, an

Washington pulled through with a temporary compromise on extending government funding on Monday, thereby continuing to fund many “non‐essential” services and programs – one of which is the National Flood Insurance Program (NFIP). However, this provides us with a three week window and if additional compromises or an agreement is not made we may find

On January 4, 2018, Attorney General Jeff Sessions issued a Memorandum which reverses the Department of Justice’s (DOJ’s) stance on enforcement of the Controlled Substances Act as it relates to medical and recreational marijuana that is legal at the state level. How this will impact federal prosecution of the marijuana industry is uncertain, but the