Top Story Compliance Related

The FFIEC has posted the edits and file specifications for 2018 CRA filings.

The CFPB has posted its 2017 annual College credit card agreements report to Congress. The Credit Card Accountability, Responsibility and Disclosure Act (“CARD Act”) requires the Bureau to submit to Congress, and to make available to the public, an annual report that lists information submitted to the Bureau concerning agreements between credit card issuers and institutions of higher education or certain organizations affiliated with such institutions. Affiliated organizations include fraternities, sororities, alumni associations, or foundations affiliated with or related to an institution of higher education.

The Department of Justice announced yesterday that it has issued a memo on federal marijuana enforcement policy announcing a return to the rule of law and the rescission of previous guidance documents. Justice's press release said that, since the passage of the Controlled Substances Act (CSA) in 1970, Congress has generally prohibited the cultivation, distribution, and possession of marijuana. In the memorandum, Attorney General Jeff Sessions directs all U.S. Attorneys to enforce the laws enacted by Congress and to follow well-established principles when pursuing prosecutions related to marijuana activities. The memo to United States Attorneys includes a list of five previous guidance documents being rescinded, including "Cole #2," issued on February 14, 2014, to all U.S. Attorneys, "Guidance Regarding Marijuana Related Financial Crimes."

The FFIEC has made a download of 2018 CRA Data Entry Software available on its software page.

The Federal Reserve Board has requested comment on proposed guidance that would clarify the Board's supervisory expectations related to risk management for large financial institutions. The guidance is part of a broader initiative to develop a new rating system for large financial institutions that will align with the post-crisis supervisory program. In August 2017, the Board invited comment on the proposed rating system, which would reflect assessments of a firm's capital, liquidity, and governance and controls and also issued a proposal identifying attributes of effective boards of directors. The supervisory expectations described in the proposed guidance, as well as those for boards of directors, would help inform the Federal Reserve's overall supervisory evaluation of a firm's governance and controls. Comments must be received by March 15, 2018. [Published at 83 FR 1351 on 1/11/2018.]

OFAC has posted new non-proliferation, Iran, and counter-terrorism designations; two designation removals and a designation update. Identification information is included in our BOL OFAC Update.

The OCC has assessed a $70 million civil money penalty against Citibank, N.A., for failing to comply with the agency’s 2012 consent order related to Bank Secrecy Act (BSA) and anti-money laundering (AML) deficiencies. See our Penalty Page for more information.

• December 27, 2017, Consent Order
• 2012 Order

Yesterday, the Office of the Comptroller of the Currency released a list of 15 Community Reinvestment Act performance evaluations that became public in December 2017. Fourteen of the evaluations carried ratings of satisfactory and one was rated needs to improve.

The Financial Action Task Force (FATF) has issued its Mutual Evaluation Report of Mexico - 2018.

• Full report
• Executive summary

The Federal Reserve Board has published its previously announced proposal to amend its Regulation M (12 CFR Part 213) to define its limited scope following enactment of the Dodd-Frank Act and the CFPB's issuance of its Regulation M. Both regulations implement the Consumer Leasing Act; the Fed's regulation only applies to certain motor vehicle dealers. Comments on the Fed's proposal are due by March 5, 2018.