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Top Story Compliance Related


FinCEN sees upward trend in wildlife trafficking SARs

FinCEN yesterday released a Financial Threat Analysis on wildlife trafficking threat patterns and trend information identified in Bank Secrecy Act data. The report aims to further inform efforts to combat wildlife trafficking and the associated movement of illicit proceeds, which are estimated to be between $7 and $23 billion per year and account for a quarter of all wildlife trade.

FinCEN’s analysis of wildlife trafficking-related Suspicious Activity Reports (SARs) indicates that wildlife trafficking is affecting the U.S. financial sector. Overall, wildlife trafficking-related SARs filed between January 2018 and October 2021 trended significantly up and SARs filed in 2021 are on track to meet or exceed the number of SARs filed in 2020 based on current trends.

FinCEN is calling attention to this threat because of: (1) its strong association with corruption and transnational criminal organizations, two of FinCEN’s national anti-money laundering and countering the financing of terrorism priorities published in June 2021; (2) a need to enhance reporting and analysis of related illicit financial flows; and, (3) wildlife trafficking’s contribution to biodiversity loss, damage to fragile ecosystems, and the increased likelihood of spreading of zoonotic diseases.


OCC updates Comptroller's Handbook

The OCC's Bulletin 2021-65, issued Monday, announced the updated "Other Real Estate Owned" booklet of the Comptroller's Handbook.

The updated booklet —

  • clarifies the definition of physical possession as it pertains to OREO properties
  • updates ownership obligations and actions as they pertain to the Fair Housing Act
  • makes other changes for clarity
  • replaces the booklet of the same title issued in September 2020 and rescinds OCC Bulletin 2020-79


SEC fines JPMorgan $125M

The SEC has announced charges against J.P. Morgan Securities LLC (JPMS), a broker-dealer subsidiary of JPMorgan Chase & Co., for widespread and longstanding failures by the firm and its employees to maintain and preserve written communications. JPMS admitted the facts set forth in the SEC’s order, acknowledged that its conduct violated the federal securities laws, and agreed to pay a $125 million penalty and implement robust improvements to its compliance policies and procedures to settle the matter.


FDIC updates mortgage servicing rules videos

The FDIC has issued FIL-79-2021 announcing its release of updates to its five technical assistance YouTube videos on the mortgage servicing rules. These videos incorporate the 2016 Mortgage Servicing Rule and the 2016 Fair Debt Collection and Practices Act Interpretive Rule and have been updated to match the FDIC’s modernized video style. The video series focuses on the small servicer as defined in Regulation Z; however, video 3 provides an overview of some of the requirements for financial institutions that lose their small servicer status. The videos range in duration from around 8 to 27 minutes.

  • Video 1 provides an overview of mortgage servicing and describes how to determine whether a servicer meets the definition of a small servicer under Regulation Z. (10:12)
  • Video 2 describes key provisions for which small servicers do not have an exception. These are the provisions with which all servicers, small and large, must comply. (27:23)
  • Video 3 provides an overview of some of the requirements that apply to large servicers and from which small servicers are exempt. This video is useful for large servicers. (12:08)
  • Video 4 describes successors in interest, including the definition of successor in interest and a general overview of what to be aware of when working with successors in interest. (8:00)
  • Video 5 provides information and examples related to developing a compliance management system that considers the mortgage servicing rules. (11:41)


OCC issues revised interagency HMDA exam procedures

The OCC has issued Bulletin 2021-63 announcing revised interagency Home Mortgage Disclosure Act examination procedures for determining compliance with HMDA and its implementing regulations. This bulletin rescinds OCC Bulletins 2010-8 and 2019-19.

The revised interagency procedures update the April 19, 2019, FFIEC interagency examination procedures for the Home Mortgage Disclosure Act. The revised procedures address changes to the effective dates for banks that meet or exceed either the closed-end mortgage loans or the open-end lines of credit loan-volume threshold in each of the two preceding calendar years:

  • Effective July 1, 2020, a bank, savings association, or credit union that originated at least 100 closed-end mortgage loans in each of the two preceding calendar years, or originated at least 500 open-end lines of credit in each of the two preceding calendar years meets or exceeds the loan-volume threshold.
  • Effective January 1, 2022, when the temporary threshold of 500 open-end lines of credit expires, a bank, savings association, or credit union that originated at least 100 closed-end mortgage loans in each of the two preceding calendar years, or originated at least 200 open-end lines of credit in each of the two preceding calendar years meets or exceeds the loan-volume threshold.

The revised procedures also address changes to a partial exemption to apply to an application or covered loan (including a purchased covered loan).


OFAC sanctions Central African Republic militia leader

On Friday, Treasury reported that OFAC had designated Ali Darassa for serious human rights abuses stemming from his leadership of the Central African Republic (CAR) based militia group, Union for Peace in the Central African Republic (UPC). UPC’s militants have killed, tortured, raped, and displaced thousands of people since 2014.

Executive Order 13667 authorizes the designation of persons contributing to the conflict in CAR, including those responsible for serious abuse or violation of human rights in CAR, or those threatening the peace, security, or stability of CAR, among other criteria.

BankersOnline's December 17, 2021, OFAC Update has identifying information for Darassa


FinCEN and OCC fine Texas Bank for BSA/AML violations

The OCC has announced a $1 million civil money penalty against CommunityBank of Texas, N.A., Beaumont, Texas, for violations of the OCC’s Bank Secrecy Act regulations. The OCC found that CommunityBank of Texas failed to adopt and implement a Bank Secrecy Act/Anti-Money Laundering system of internal controls to assure ongoing compliance with the Bank Secrecy Act and its implementing regulations. Such deficiencies resulted in CommunityBank’s failure to timely file complete suspicious activity reports for approximately $100 million of suspicious activity. The OCC’s civil money penalty is separate from, but coordinated with, a settlement between CommunityBank and FinCEN.

FinCEN has announced it has assessed an $8 million civil money penalty on the bank for willful violations of the Bank Secrecy Act (BSA) and its implementing regulations.

The bank admitted that it willfully failed to implement and maintain an effective anti-money laundering (AML) program that was reasonably designed to guard against money laundering. The bank also admitted that it willfully failed to report hundreds of suspicious transactions to FinCEN involving illegal financial activity by its customers and processed by, at, or through the bank even after the bank became aware that certain customers were subjects of criminal investigations. The violations occurred from at least 2015 through 2019 and caused millions of dollars in suspicious transactions to go unreported to FinCEN in a timely and accurate manner, including transactions connected to tax evasion, illegal gambling, money laundering, and other financial crimes.


Annual CRA asset-size thresholds updates

The Federal Reserve Board and the FDIC have announced the 2022 updated asset-size thresholds used to define "small bank" and "intermediate small bank" under their Community Reinvestment Act (CRA) regulations.

Annual adjustments to these asset-size thresholds are based on the average change in the Consumer Price Index for Urban Wage Earners and Clerical Workers (CPI-W), which is a measure of inflation.

As a result of the 4.73 percent increase in the CPI-W for the period ending in November 2021, the definitions of small and intermediate small banks for CRA examinations will change, effective January 1, 2022, as follows:

  • Small bank means an institution that, as of December 31 of either of the prior two calendar years, had assets of less than $1.384 billion.
  • Intermediate small bank means a small institution with assets of at least $346 million as of December 31 of both of the prior two calendar years and less than $1.384 billion as of December 31 of either of the prior two calendar years.

PUBLICATION Update: Published at 86 FR 71813 on 12/20/2021.


OFAC targets 8 Chinese tech firms

On Thursday, Treasury announced that OFAC has identified eight Chinese technology firms under the authority of Executive Order 13959, as amended by E.O. 14032. These eight entities actively support the biometric surveillance and tracking of ethnic and religious minorities in China, particularly the predominantly Muslim Uyghur minority in Xinjiang. As a result of yesterday’s action, U.S. persons will be prohibited from purchasing or selling certain publicly traded securities connected with these entities, as described in E.O. 13959, as amended.

For identification information on the eight identified entities, see the December 16, 2021, BankersOnline OFAC Update.


Interagency statement on institutions affected by tornadoes

The Federal Reserve Board, Conference of State Bank Supervisors (CSBS), FDIC, NCUA, and the OCC (the Agencies) on Wednesday issued an Interagency Statement that they recognize the serious impact of tornadoes on the customers and operations of many financial institutions and will provide appropriate regulatory assistance to affected institutions subject to their supervision. The agencies encourage institutions operating in the affected areas to meet the financial services needs of their communities.
A complete list of the affected disaster areas can be found at
The assistance that the Agencies will provide include guidance and flexibility in the following areas:

  • Lending
  • Temporary facilities
  • Publishing requirements
  • Regulatory reporting requirements
  • Community Reinvestment Act
  • Investments

For more information, refer to the Interagency Supervisory Examiner Guidance for Institutions Affected by a Major Disaster available on the following websites: CSBS; FDIC; FRB; OCC; and NCUA.
Press release and related links:


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