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Today is: October 14, 2019  


BCG Monthly Newsletter

Bankers’ Compliance Group® is pleased to provide its members with a monthly online Newsletter that keeps members informed on current topics related to Dodd-Frank Regulatory Reform, Consumer Finance, Operations, Commercial Lending, etc. BCG members can view the current Newsletter by selecting the download button below.

October 2019 Newsletter Highlights    Download Newsletter  

HMDA Quarterly Reporting Begins January 1, 2020
On September 25, 2019, the CFPB released the 2020 HMDA Filing Instructions Guide (FIG) and the Supplemental Guide for Quarterly Filers (Supplemental Guide). The FIG is a technical resource to assist HMDA filers that the Bureau publishes every year.

Private Flood Insurance & Compliance Aid Statement
Question: In order to rely on a private flood insurance (PFI) policy’s compliance aid statement (CAS), how similar must it be to the CAS in the flood insurance regulations?

FRB and CFPB Amend Regulation CC for Inflation
On July 3, 2019, the FRB and CFPB published a final rule amending Regulation CC which implements the Expedited Funds Availability Act (EFA Act). 84 FR 31687. Technical corrections to the final rule were published in the Federal Register on August 29, 2019. 84 FR 45403.

Regulation E Error Investigation
Question: Under Regulation E, a financial institution generally has 45 days from receipt of a notice of error to investigate and determine whether an error occurred. Section 1005.11(c). However, the investigation time frame is automatically extended to 90 days for notices of error involving an electronic fund transfer that resulted from a “point-of-sale debit card transaction.” Section 1005.11(c)(3)(ii)(b).

California Establishes a Public Bank
On October 2, 2019, California’s Governor Gavin Newsom signed AB 857 which will allow certain governmental entities to form “public banks.” The bill’s passage makes California the second state after North Dakota to offer public banking. AB 857 defines the term “bank” for purposes of California’s Financial Institutions Law and Banking Law to include a “public bank.”

Federal Credit Unions Can Offer PALs II Loans Starting December 1
On October 1, 2019, the NCUA approved a second final payday alternative loan (PAL) rule to allow federal credit unions (FCUs) to offer an additional type of PAL to their members). 84 FR 51942. A “payday loan” generally refers to a short-term, small-dollar loan repayable in one or more installments with repayment secured by a pre- or post-dated check or a preauthorized electronic fund transfer from the borrower’s share account.

Table of Contents

Consumer Finance

  • HMDA Quarterly Reporting Begins January 1, 2020
  • CFPB Issues Policies to Promote Innovation and Facilitate Regulatory Compliance
  • Bureau Issues 19th Edition of its Supervisory Highlights
  • NFIP Extended Through November 21, 2019
  • CFPB Updates its HMDA Webinars for the Regulatory Relief Act and its 2018 Rule

Consumer Finance Q&A

  • Private Flood Insurance & the Compliance Aid Statement
  • Prepaid vs. Prepaid Finance Charges

Banking Operations & FinTech

  • FRB and CFPB Amend Regulation CC for Inflation
  • Judicial Council Adjusts the Automatic Exemption Amounts for Certain Judgment Levies
  • IRS Issues Guidance on Nonresident Alien Depositor Foreign TIN and DOB Requirements
  • DBO Outlines Proactive Steps for Financial Institutions to Mitigate Data Breaches

Banking Operations & FinTech Q&A

  • Regulation E Error Investigation

Corporate Governance

  • California Establishes a Public Bank
  • Eleventh Circuit Upholds FDIC’s $5 Million Jury Award Against a Bank’s Board of Directors
  • FDIC Proposes Amendments to Small Bank Assessment Credit Regulations
  • Two Challenges to the OCC Fintech Charter and Two Different Rulings
  • OCC Implements “Covered Savings Associations”

Credit Unions

  • Federal Credit Unions Can Offer PALs II Loans Starting December 1
  • NCUA Issues Regulatory Alert to FCUs Serving Hemp Businesses
  • ABA Petitions for En Banc Hearing Over NCUA’s FOM Rule








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