Special Release

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SCRA Notice Changes

We are not sure when it occurred, but HUD slipped in two changes to the SCRA notice since it was last changed in March 2018. Both changes are in the final section within two bullet points. In the first bullet point, the website address for the Military Legal Assistance Office Locator was shortened, presumably to […]

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New Hemp-related Business Guidance

On June 29, 2020, FinCEN published FIN-2020-G001 providing guidance for obtaining due diligence information for hemp-related businesses. The BSA industry has wrestled with cannabis and its derivative rules since FinCEN’s initial 2014 guidance for banking marijuana-related businesses. Between 2014 and 2018, hemp was equated with marijuana since both are derived from the same plant. However,

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covid-19

Limited Open-End Credit eSign Exemption Due to COVID-19

The Consumer Financial Protection bureau released a Statement on Supervisory and Enforcement Practices Regarding Electronic Credit Card Disclosures in Light of the COVID-19 Pandemic. This is described as a temporary and targeted flexibility for credit card issuers during this pandemic regarding the electronic provision of certain disclosures required to be in writing. Regulation Z generally

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fraud being stopped

FinCEN Guidance on Medical Scams and COVID-19

As we continue to adjust with the evolving pandemic, FinCEN published two documents to keep awareness high. The May 18, 2020 Notice provides a current update to meet the various BSA reporting, recordkeeping and monitoring requirements.  Here are a few of the key points: BSA Reporting Requirements – As noted in TCA’s earlier article BSA

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