Compliance Action, Volume 25, Number 4

BSA
Mandatory Cease and Desist Order for BSA/AML Compliance Program Violations

By Nancy Castiglione, CRCM

A joint statement issued by the regulatory agencies regarding the mandatory issuance of cease and desist orders for BSA/AML violations makes it clear that the agencies will take action if an institution's BSA/AML compliance program falls short.

Compliance Notes

• FedNow Service Approved by FRB
• Due Diligence for PEPs
• FDIC’s Criminal Offenses Statement of Policy Regulation
• HMDA FIG Published

Action Training
UDAP/UDAAP Training

By Nancy Castiglione, CRCM

The OCC's Handbook on Unfair or Deceptive Acts or Practices/Unfair, Deceptive, or Abusive Acts or Practices, published in June, describes the regulator's supervisory approach and contains exam procedures for supervised institutions and other useful reference information.

CRA
OCC Community Reinvestment Act Assessment Area Changes

By Nancy Castiglione, CRCM

Under the new OCC Community Reinvestment Act Regulation that goes into effective October 1, 2020, the methods, options, and limitations on how a national bank may define its assessment area are significantly changed.

Compliance Calendar

In the Editor's Opinion
Bankers as First Responders

By Nancy Castiglione, CRCM

There are lots of unsung heroes during the COVID crisis. The people and institutions that are working to keep the economy and our individual support systems functioning are among those who deserve our recognition and appreciation.

Regulatory Guidance
The Paycheck to Paycheck Loan

By Nancy Castiglione, CRCM

In case you missed it, there has been some recently rescinded guidance and some recently issued guidance related to small-dollar, aka payday, loans.

Compliance Online
Free FDIC Insurance Seminars