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Banker's Toolbox solidifies its position as the premier solution for fast-growing financial institutions with the release of BAM+ 4.0 upgrade.
Banker's Toolbox continues to lead the BSA/AML and Fraud prevention marketplace with the release of BAM+ 4.0. This solution provides increased detection with more versatility, transparency and control. BAM+ 4.0 also boasts a new customer due diligence platform, Due Diligence Manager, which will keep institutions compliant with the impending beneficial ownership mandates. (Read full press release here.)

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Caution on prospective Venezuelan digital currency

OFAC has posted a new Frequently Asked Question relating to a December 2017 announcement by Venezuelan President Nicolas Maduro of plans for the Venezuelan government to launch a digital currency. Because the proposed currency would reportedly carry rights to receive commodities in specified quantities at a later date, OFAC has determined that the currency would appear to be an extension of credit to the Venezuelan government, and U.S. persons that deal in the prospective Venezuelan digital currency may be exposed to U.S. sanctions risk.


OCC releases monthly list of enforcement actions

The OCC has issued a list of new enforcement actions taken against OCC-supervised institutions and individuals currently or formerly affiliated with OCC-supervised institutions. Two civil money penalty orders were included—a previously announced $70 million BSA-related penalty levied against Citibank, NA, Sioux Falls, SD, and a $10,000 penalty imposed on the former CFO and director of a bank in Cuba, MO.

Also included were two personal cease and desist orders, a Prompt Corrective Action directive, and a removal/prohibition order issued to a former Ohio bank teller who stole $13,000 using unauthorized withdrawals from customer accounts.


Interagency statement on implications of new tax law

FDIC FIL-6-2018 and OCC Bulletin 2018-2 were issued January 18, 2018, distributing an Interagency Statement on Accounting and Reporting Implications of the New Tax Law, issued by the OCC, Federal Reserve Board, and the FDIC. Changes required as a result of the new law, which was enacted on December 22, 2017, are relevant to December 31, 2017, financial statements and regulatory reports, including Call Reports. Among other things, the guidance clarifies

  • that changes in deferred tax assets and deferred tax liabilities resulting from the lower corporate income tax rate, and other applicable provisions of the new tax law, should be reflected in an institution’s income tax expense in the period of enactment.
  • how to resolve the disproportionate tax effects in accumulated other comprehensive income as a result of the remeasurement of deferred tax assets and liabilities.
  • the impact of the new tax law on regulatory capital.


Bureau to forgo Fed funding for Q2

In a marked departure from earlier practice, the CFPB will not seek funding from the Federal Reserve for its second quarter of FY 2018 operations. In a letter to Federal Reserve Board Chair Janet Yellen, Acting CFPB Director Mick Mulvaney notified the Board that the Bureau is "requesting $0." Under the Dodd-Frank Act, subject to a funding cap, the Fed is required to transfer to the Bureau each quarter "the amount determined by the [CFPB] Director to be reasonably necessary to carry out the authorities of the Bureau under Federal consumer financial law, taking into account such other sums made available to the Bureau from the preceding year (or quarter of such year.)" Mulvaney states in his letter that he has been assured that the Bureau has sufficient funds to carry out its statutory mandates for the quarter.


December residential construction activity

HUD and the Census Bureau have jointly released statistics on new residential construction for December 2017.

  • Building Permits: Privately owned housing units authorized by building permits in December were at a seasonally adjusted annual rate of 1,302,000, 0.1 percent below the revised November rate of 1,303,000 but 2.8 percent above the December 2016 rate of 1,266,000. Single-family authorizations in December were at a rate of 881,000; this is 1.8 percent above the revised November figure of 865,000. Authorizations of units in buildings with five units or more were at a rate of 382,000 in December. An estimated 1,263,400 housing units were authorized by building permits in 2017. This is 4.7 percent above the 2016 figure of 1,206,600.
  • Housing Starts: Privately owned housing starts in December were at a seasonally adjusted annual rate of 1,192,000. This is 8.2 percent below the revised November estimate of 1,299,000 and 6.0 percent below the December 2016 rate of 1,268,000. Single-family housing starts in December were at a rate of 836,000, 11.8 percent below the revised November figure of 948,000. The December rate for units in buildings with five units or more was 352,000. An estimated 1,202,100 housing units were started in 2017. This is 2.4 percent above the 2016 figure of 1,173,800.
  • Housing Completions: Privately owned housing completions in December were at a seasonally adjusted annual rate of 1,177,000. This is 2.2 percent above the revised November estimate of 1,152,000 and 7.4 percent above the December 2016 rate of 1,096,000. Single-family housing completions in December were at a rate of 818,000, 4.3 percent above the revised November rate of 784,000. The December rate for units in buildings with five units or more was 346,000. An estimated 1,152,300 housing units were completed in 2017, 8.7 percent above the 2016 figure of 1,059,700.


OCC semiannual risk perspective

The OCC has issued its Semiannual Risk Perspective for Fall 2017, which covers risks facing national banks and federal savings associations based on data as of June 30, 2017. The report presents data in four main areas: the operating environment, bank performance, trends in key risks, and supervisory actions. It focuses on issues that pose threats to those financial institutions regulated by the OCC and is intended as a resource to the industry, examiners, and the public.

Highlights include:

  • The credit environment continues to be influenced by aggressive competition, tighter spreads, and slowing loan growth. These factors are driving incremental easing in underwriting practices and increasing concentrations in select loan portfolios—leading to heightened risk if the economy weakens or markets tighten quickly.
  • Operational risk continues to challenge banks because of increasing complexity of cybersecurity threats, use of third-party service providers, and increasing concentrations in third-party service providers for some critical operations.
  • Compliance risk remains elevated as banks continue to manage money laundering risks, as well as consumer compliance risks, particularly due to the increasing complexity in consumer compliance regulations.


FTC annual privacy and data security update

The Federal Trade Commission has released its annual report summarizing its privacy and data security work in 2017.


CFPB scam alert

The Bureau has posted a warning that a lottery is using a CFPB employee’s name. The article describes the scam as having four phases, or steps.

  • A victim receives a call stating that he or she has won a lottery or sweepstakes prize.
  • Several other calls will follow. One of these calls may come from an imposter claiming to be Stacy Canan, or another CFPB or U.S. government agency official who confirms that the victim has won the prize.
  • Later, the victim is told that to collect the prize, he or she must pay taxes upfront.
  • The victim sends the money to pay the taxes and never hears from any of the callers again.


HUD offering $25M in lead-paint hazard grants

HUD has announced the availability of $25 million in grants to identify and eliminate lead-based paint hazards in public housing. These funds are offered through HUD's Public and Indian Housing Lead-Based-Paint Capital Fund Program. HUD will award grants to approximately 30 recipients ranging from $25,000 to $1 million. Applications are due March 20, 2018.


Taiwanese bank to pay $29M CMP for AML violations

The Federal Reserve Board has announced it has issued a consent cease and desist order and a $29 million penalty against the U.S. operations of Mega International Commercial Bank Co., Ltd., of Taipei, Taiwan, for anti-money laundering violations and required the firm to improve its anti-money laundering oversight and controls. For further details, see "Mega International Commercial Bank pays $29M BSA penalty," in our Penalty pages.


Industrial production increases

The Federal Reserve has issued the December 2017 G.17 report, which indicates Industrial production rose 0.9 percent, even though manufacturing output only edged up 0.1 percent. Revisions to mining and utilities data altered the pattern of growth for October and November, but the level of the overall index in November was little changed. For the fourth quarter as a whole, total industrial production jumped 8.2 percent at an annual rate after being held down in the third quarter by Hurricanes Harvey and Irma. At 107.5 percent of its 2012 average, the index has increased 3.6 percent since December 2016 for its largest calendar-year gain since 2010.


January Beige Book published

The Beige Book for January 2018 has been released by the Federal Reserve Bank of Atlanta. The summary of commentary on current economic conditions is published by the Federal Reserve Board eight times per year. Each Reserve Bank gathers anecdotal information on current economic conditions in its District through reports from Bank and Branch directors and interviews with key business contacts, economists, market experts, and other sources. The Beige Book summarizes this information by District and sector. An overall summary of the twelve district reports is prepared by a designated Federal Reserve Bank on a rotating basis.


EEOC raises penalty for notice-posting violations

The Federal Equal Employment Opportunity Commission has published a final rule in this morning's Federal Register, increasing the civil money penalty for a violation of the notice-posting requirements in Title VII of the Civil Rights act of 1964, the Americans with Disabilities Act, and the Genetic Information Non-Discrimination Act, from $534 to $545, effective February 20, 2018.


CFPB to reconsider Payday Rule

Yesterday, the effective date of one portion of the "Payday, Vehicle Title, and Certain High-Cost Installment Loans" regulation (Payday Rule), the CFPB issued a statement that it "intends to engage in a rulemaking process so that the Bureau may reconsider the Payday Rule." The Bureau said it will entertain requests for waivers from the rule's April 16, 2018, deadline for submissions for preliminary approval to become a registered information system under the Payday Rule. Under the Rule, registered information systems are special-purpose consumer reporting agencies with whom covered lenders under the rule are required to file credit history and from which credit history information is to to be obtained for underwriting certain types of loans under the rule.


NMLS call center closed early yesterday

Due to severe weather conditions in the East Texas location of the NMLS Call Center, the center closed early at 6:00 p.m. ET on January 16, 2018. The early closure allowed call center management and staff the opportunity to return to their homes before sub-freezing temperatures further degraded road conditions. It is expected that the NMLS Call Center will re-open on time on Wednesday, January 17 at 9:00 a.m. ET. Staffing levels may be lower than normal but wait times should return to normal by late morning.


NMLS maintenance release this weekend

NMLS Federal Registry Resources posted a notice yesterday that NMLS Maintenance Release 2018.1 is scheduled to be installed Saturday, January 20. The release contains several system maintenance upgrades, which can be reviewed in the NMLS January Maintenance Release Notes.


FED 360° released

The current issue of FED 360° includes these articles

  • Learn how you can improve the security of the U.S. payment system
  • Federal Reserve Payments Study: 2017 Supplement shows accelerated credit card use
  • New report replaces the Same Day Originated Batch Report
  • Check this out: Savings Bonds News You Can Use
  • Attend a webinar on the Minneapolis Fed's Payments Fraud Mitigation Survey results
  • 2018 marks the ninth year of the American the Beautiful Quarters Program
  • Fed Facts: How is the Fed chair nominated?

FED 360° replaces FedFlash and FedFocus.


Bureau to ask for performance evaluations

The CFPB has announced it will issue a "call for evidence" to ensure the Bureau is fulfilling its proper functions to best protect consumers. The Bureau plans to publish a series of Requests for Information (RFIs) seeking comment on the Bureau's enforcement, supervision, rulemaking, market monitoring, and education activities. Acting Director Mick Mulvaney said, "Much can be done to facilitate greater consumer choice and efficient markets, while vigorously enforcing consumer financial law in a way that guarantees due process. I look forward to receiving public comments in response to this call for evidence and encourage all interested parties to participate."

In the first RFI, the Bureau will seek comment on Civil Investigative Demands, which are issued during an enforcement investigation.


Goldmann Sachs Bank USA pays Flood Act penalty

The Federal Reserve Board has announced it has issued to Goldmann Sachs Bank USA, of New York, an order to pay a $90,000 civil money penalty for a pattern or practice of violations of the National Flood Insurance Act. See our Penalty Page for more information.


Treasury adds Iran and Proliferation designations

The Department of the Treasury has announced that its Office of Foreign Assets Control (OFAC) designated on Friday fourteen individuals and entities in connection with serious human rights abuses and censorship in Iran, and support to designated Iranian weapons proliferators. The actions were taken pursuant to Executive Order (E.O.) 13553, which targets serious human rights abuses by the Government of Iran; E.O. 13606, which targets grave human rights abuses by the Governments of Iran and Syria via information technology; E.O. 13628, which targets, among other things, censorship or other activities that prohibit, limit, or penalize the exercise of freedom of expression or assembly by citizens of Iran, or that limit access to print or broadcast media; and E.O. 13382, which targets proliferators of weapons of mass destruction and their supporters.

For identification of the individuals and entities designated, see our OFAC Update.


Fed ends actions against loan servicers, penalizing five

The Federal Reserve Board on Friday announced the termination of enforcement actions related to residential mortgage loan servicing and foreclosure processing issued in 2011 and 2012 against 10 banking organizations. The Board also announced civil money penalties totaling $35.1 million against five of these 10 organizations that had not yet been fined for their mortgage servicing deficiencies related to those enforcement actions. With the penalties announced today, the Board has now assessed penalties totaling approximately $1.1 billion against all Federal Reserve supervised firms under mortgage servicing enforcement actions.

The 10 banking organizations are: Ally Financial Inc.; Bank of America Corporation; CIT Group, Inc. (as successor to IMB HoldCo LLC); The Goldman Sachs Group, Inc.; HSBC North America Holdings, Inc.; JPMorgan Chase & Co.; Morgan Stanley; The PNC Financial Services Group, Inc.; SunTrust Banks, Inc.; and U.S. Bancorp. The termination of the actions was based on evidence of sustainable improvements in the firms' oversight and mortgage servicing practices.

The civil money penalties announced today are: $14 million against Goldman Sachs; $8 million against Morgan Stanley; $5.2 million against CIT (as successor to IMB); $4.4 million against U.S. Bancorp; and $3.5 million against PNC.

Also on Friday, the Board announced the termination by the Board and other federal financial regulatory agencies of joint enforcement actions issued in 2011 against Lender Processing Services, Inc. (LPS), which was succeeded by ServiceLink Holdings, LLC, and against MERSCORP Holdings, Inc., formerly known as MERSCORP, Inc. (MERS). These enforcement actions addressed deficiencies in the foreclosure-related services LPS and MERS each provided to entities regulated by the agencies. The termination of the actions was based on evidence of sustainable improvements in the foreclosure-related practices of LPS and MERS.


FSOC annual report

The Financial Stability Oversight Council (FSOC) has announced the publication of its 2017 annual report. The report describes significant financial market and regulatory developments, potential emerging threats to U.S. financial stability, recommendations to promote financial stability, and the activities of the FSOC. The report was developed collaboratively by the members of the FSOC and their agencies and respective staff and was approved unanimously by voting members of the FSOC. The report notes that the U.S. financial regulatory system should promote economic growth by preventing financial crises and also minimizing regulations that increase costs without commensurate benefits.

Additional recommendations in the annual report include:

  • The FSOC supports the creation of a private sector council of senior executives to collaborate with regulators and focus on the ways that cyber incidents could impact businesses.
  • Financial regulators should ensure that financial institutions have sufficient capital and liquidity to reduce their vulnerability to economic and financial shocks. Additionally, regulators should continue to monitor and assess the impact of rules on financial institutions and markets.
  • Regulators should continue to evaluate whether existing rules and standards for central counterparties and their clearing members are sufficiently robust to mitigate potential threats to financial stability.
  • The Securities and Exchange Commission should monitor and assess the effectiveness of money market mutual fund reforms that were implemented last year.
  • Regulators and market participants should complete work on alternative reference rates, and take appropriate steps to mitigate disruptions associated with the transition to a new reference rate.
  • Regulators and market participants should continue work to improve the coverage, quality, and accessibility of financial data, as well as data sharing between and among relevant agencies.


FATF report on financing of terrorist recruitment

The Financial Action Task Force (FATF) has issued a report that identifies the most common methods of recruitment used by terrorist organizations and terrorist cells, and the costs associated with these different methods and techniques of terrorist recruitment. Using input collected from authorities within the FATF Global Network, the report increases understanding of terrorist organizations' funding needs to recruit members and supporters. In some cases, these funding needs are minimal.


FHFA adjusts cap for community financial institutions

The Federal Housing Finance Agency (FHFA) has published a Federal Register notice adjusting the cap on average total assets that is used in determining whether a Federal Home Loan Bank member qualifies as a “community financial institution” (CFI) to $1,173,000,000, based on the annual percentage increase in the Consumer Price Index for all urban consumers (CPI-U), as published by the Department of Labor (DOL). These changes took effect on January 1, 2018.

The Federal Home Loan Bank Act confers upon insured depository institutions that meet the statutory definition of a CFI certain advantages over non-CFI insured depository institutions in qualifying for Bank membership, and in the purposes for which they may receive long-term advances and the collateral they may pledge to secure advances.


NCUA adjusts CMP caps

The National Credit Union Administration has published a final rule to adjust the maximum amount of each civil monetary penalty (CMP) within its jurisdiction to account for inflation. The rule became effective on January 15, 2018.


OCC publishes notice of CMP inflation adjustments

The Office of the Comptroller of the Currency has published in the January 12, 2018, Federal Register a notice of inflation adjustments to civil money penalty amounts.


HUD awards $2B to homeless assistance programs

HUD has announced the award of a record $2 billion to support more than 7,300 local homeless assistance programs across the nation. HUD's Continuum of Care grants provide critically needed support to local programs on the front lines of serving individuals and families experiencing homelessness.


Interactive tools added to FRB website

The Federal Reserve Board has added three new tools to its web site to provide interactive access to data from the Board's Financial Accounts of the United States (Z.1) release, which tracks the aggregate wealth of U.S. households and other economic sectors. The data visualization tools show, at a glance, the evolution of key financial statistics, changes in household debt in recent years for each county and metro area in the United States, and developments in state and local pension funding for each state.


New SEC commissioners sworn in

The Securities and Exchange Commission has announced that Robert J. Jackson Jr. and Hester M. Peirce were sworn into office as SEC Commissioners on January 11 by Commission Chairman Jay Clayton. They were nominated to the SEC by the president and their nominations were confirmed by the U.S. Senate on December 21.


Bureau offering email course on consumer budgeting

The CFPB has announced it will start offering an email course, "Get a Handle on Debt Boot Camp," to help consumers create a budget, track spending, and learn strategies for paying down debt. The course is scheduled to begin in February.


New withholding tables issued

The Department of the Treasury has announced that the IRS has sent new tax withholding guidance to employers to implement tax cuts and other provisions of the Tax Cuts and Jobs Act. Treasury encouraged employers to start using the new withholding tables as soon as possible, but no later than February 15, 2018. The IRS intends to release a new withholding calculator by the end of February, for employees to use to update their withholding information as needed. The IRS said the tables are designed to produce the correct amount of tax withholding, and to avoid over- and under-withholding of tax as much as possible.


CFPB updates CMP caps

The Consumer Financial Protection Bureau has published in the January 12, 2017, Federal Register a final rule adjusting for inflation the maximum amount of each civil penalty within the Bureau’s jurisdiction. These adjustments are required by the Inflation Adjustment Act. The inflation adjustments mandated by the Inflation Adjustment Act serve to maintain the deterrent effect of civil penalties and to promote compliance with the law. The rule is effective January 15, 2017.

As examples of the inflation adjustments, the $50 per violation statutory civil money penalty for failure to provide an annual escrow statement under RESPA will be increased to $92, with an annual cap, originally $100,000, increased to $184,767. Intentional failures to provide the statement can result in penalties up to $185 per violation with no annual cap, an increase from the statutory amount of $100. The statutory maximum penalty of $10,000 per day for a first violation of the appraisal independence requirements under the Truth in Lending Act will be increased to $11,279.


Judge denies injunction for CFPB's English

Judge Timothy J. Kelly, of the United States District Court for the District of Columbia yesterday denied CFPB Deputy Director Leandra English's motion for a preliminary injunction that would restrain the president from appointing Mick Mulvaney as acting director of the CFPB, stating that English is unlikely to succeed in her case brought to enjoin the president from such an appointment. The underlying case pits a provision of the Dodd-Frank Act that provides that the Deputy Director of the agency shall "serve as acting Director in the absence or unavailability of the Director," against the Federal Vacancies Reform Act of 1998, under which Mulvaney was appointed acting Director by the president.


Supervisory Insights focus on credit MIS

The FDIC has issued the Winter 2017 issue of Supervisory Insights, which includes articles on credit Management Information Systems (MIS) and recent results from the FDIC's Credit and Consumer Products/Services Survey. The survey results show that about one in ten banks may be considered to be at "high" credit risk, down from about 42 percent in 2010, when banks were in the middle of a backlog of classified loans. However, almost 70 percent of banks had either a credit or funding concentration.

The article on credit MIS emphasized the need for incorporating forward-looking risk indicators, rather than relying on delinquencies and charge-offs, which tend to be lagging indicators.


Leadership of Reserve Banks announced

The Federal Reserve Board has announced the appointment of the chairs and deputy chairs of the twelve Federal Reserve Banks for 2018.


FDIC publishes CMP inflation adjustments

The FDIC published in the January 12, 2018, Federat Register a final rule making civil money penalty inflation adjustments for violations of statutes, rules and orders within its jurisdiction. The rule amends § 308.116 of the FDIC's Rule and Regulations at 12 CFR Part 308. The amendment affects penalties assessed after January 15, 2018, for violations that occurred on or after November 2, 2015.


Fed releases minutes of discount rate meetings

The Federal Reserve Bpard has released the minutes of its discount rate meetings from December 4 and 13, 2017.


Board rule increases CMP maximums

The Federal Reserve Board has published a final rule [83 FR 1182] adjusting the amount of each civil money penalty maximum provided by law within its jurisdiction to account for inflation, as required by the Federal Civil Penalties Inflation Adjustment Act Improvements Act of 2015. The adjustments apply to penalties assessed on or after January 10, 2018, for violations occurring on or after November 2, 2015. For example, the statutory $2,000 maximum penalty per violation for violations of requirements to require certain violations of the National Flood Insurance Act, which had increased to $2,056 in January of last year, has now been set at $2,133 per violation. A table of the maximum CMP amounts is found in § 263.65 of the Board's Rules of Practice for Hearings, at 12 CFR Part 263.


Unauthorized banking alert

The OCC has issued an Alert regarding an entity calling itself Bluegate Industrial Bank USA, N.A., which purports to be an online financial institution offering regular banking products as well as loan services. Bluegate Industrial Bank USA, N.A., is not a licensed or chartered bank. for more information, see our Alert Page.


Consumer credit growth

The Federal Reserve has issued November 2017 G.19 consumer credit data, which indicate that consumer credit increased at a seasonally adjusted annual rate of 8-3/4 percent. Revolving credit increased at an annual rate of 13-1/4 percent, while nonrevolving credit increased at an annual rate of 7-1/4 percent.


FDIC proposes Section 19 policy update

The FDIC has published a Notice in today's Federal Register that it proposes to update its Statement of Policy (SOP) issued pursuant to Section 19 of the Federal Deposit Insurance Act. Section 19 prohibits, without the prior written consent of the FDIC, any person from participating in banking who has been convicted of a crime of dishonesty or breach of trust or money laundering, or who has entered a pretrial diversion or similar program in connection with the prosecution for such an offense. The FDIC is proposing to expand its current de minimis exception to encompass insufficient funds checks of aggregate moderate value; small dollar, simple theft; and isolated, minor offenses committed by young adults. These carefully measured changes are intended to reduce regulatory burden by decreasing the number of covered offenses that will require an application, while ensuring that insured institutions are not subject to risk by convicted persons. Comments on the proposal are due by March 9, 2018.


Four Venezuelan officials sanctioned

On Friday, January 5, acting under Executive Order (E.O.) 13692, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) designated four current or former Venezuelan government officials associated with corruption and repression in Venezuela. As a result of Friday’s actions, all assets of the designated current or former officials of the Government of Venezuela that are subject to U.S. jurisdiction are frozen, and U.S. persons are generally prohibited from dealing with them. For the four individuals' identification information, see our OFAC Update.


FDIC releases 67 CRA evaluations

The FDIC has released a list of 67 state nonmember banks recently evaluated for compliance with the Community Reinvestment Act (CRA). The list covers ratings assigned in October 2017. Seven of the banks listed received outstanding evaluation ratings. The remaining 60 institutions received satisfactory ratings.


OCC counterfeit cashier's check alert

The OCC has issued an alert about counterfeit cashier's checks purporting to be drawn on BNC National Bank, Glendale, Arizona, that have been reported by that bank. Details from the alert are posted in our Alerts and Counterfeits pages.


Q1 and Q2 Call Report revisions

FDIC FIL-4-2018, issued on Friday, addresses revisions to the consolidated reports of condition and income (Call Report) for March and June 2018. The FIL applies to all FDIC-supervised banks and savings associations, including community institutions. Highlights include:

  • The burden-reducing changes being implemented by the agencies apply to the new FFIEC 051 Call Report as well as the FFIEC 041 and FFIEC 031 Call Reports.
    • These revisions will take effect as of the June 30, 2018, report date, which is the proposed effective date of further burden-reducing Call Report revisions about which the agencies recently requested comment.
    • For small institutions filing the FFIEC 051, the reporting changes will affect approximately seven percent of the data items collected.
  • Revisions will be made to several Call Report schedules as of March 31, 2018, in response to changes in the accounting for equity securities and other equity investments that take effect for some institutions in the first quarter of 2018.
  • The agencies' June 2017 proposal also included an instructional revision for determining past-due status for regulatory reporting purposes. Based on the comments received on this aspect of the proposal, the agencies are not introducing this proposed instructional revision at this time.
  • Redlined copies of the FFIEC 051, FFIEC 041, and FFIEC 031 report forms showing the Call Report revisions and the related draft instructions are available on the FFIEC's website ( This website also includes draft revised instructions to implement the agencies' regulatory capital transitions final rule in the Call Report for March 31, 2018.
  • Review FIL-2-2018 for additional information about the changes to the Call Report requirements.


CFPB posts report on college card agreements

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.


FFIEC 2018 CRA edits and file specs

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


OCC CRA ratings for 15 banks

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.


Citibank pays $70M BSA/AML CMP

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.


OFAC designations, removals and updates

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.


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