Newsletters

04.21.20

Preparing for Post-COVID-19 Regulatory Exams: What Banks Need to Do Now

While we are still immersed in the economic fallout of the COVID-19 pandemic, banks must look ahead to a post-COVID-19 world and, in particular, the next 12-to-24-month regulatory exam cycle, when federal and state banking regulators will have the opportunity to take their first very close look at ...


04.21.20

COVID-19 Credit Reporting: State AGs Might Strictly Enforce FCRA Even Where CFPB Declines

Relaxed Fair Credit Reporting Act (FCRA) credit reporting enforcement during COVID-19? Not so fast, say 23 state attorneys general (AGs).


04.21.20

Anti-Money Laundering: What You Need to Know Now About the Updated BSA/AML Examination Manual




04.20.20

COVID-19 Warning to Mortgage Servicers

Just when you thought that federal agencies were softening their stance on enforcement during the crisis, the Consumer Financial Protection Bureau (CFPB) and the Federal Housing Finance Agency (FHFA) took a figurative shot across the bow.


04.20.20

Fair Lending: CFPB Issues Final Rule Raising HMDA Thresholds

Keeping busy despite the pandemic, the Consumer Financial Protection Bureau (CFPB) has promulgated its final rule raising the loan-volume coverage thresholds for financial institutions reporting data under the Home Mortgage Disclosure Act (HMDA) and Regulation C.


04.14.20

Bank Secrecy Act Compliance Issues for Small-Business Lending Under the CARES Act

With many banks and credit unions electing to limit Paycheck Protection Program (PPP) loans to existing customers, many nonbank lenders are scrambling to fill the gap and take part in the $349 billion program prior to the end of the application period on June 30, 2020.


04.13.20

New Federal Reserve Credit Facilities Providing up to $2.3 Trillion in Additional COVID-19 Funding

On April 9, the Federal Reserve took the following actions to provide up to an additional $2.3 trillion in economic aid to support the economy during the coronavirus pandemic.


04.10.20

Regulators Facilitate Favorable Capital Treatment For Banks Participating in the PPP

In the federal government’s ongoing effort to facilitate participation by depository institutions in its signature Paycheck Protection Program (PPP), on April 9, 2020, the Office of the Comptroller of the Currency, the Federal Deposit Insurance Corporation and the Federal Reserve Board (FRB) ...


04.09.20

False Claims Act Liability for Lenders Participating in the CARES Act Paycheck Protection Program

Although federal regulators repeatedly have assured banks that they can make Paycheck Protection Program (“PPP”) loans without fear of later reprisals, there remains the potential for liability under the federal False Claims Act.


04.08.20

Interagency Statements on Residential Mortgage Servicing and Loan Modification and Reporting

Residential mortgage servicers have now received critical new guidance regarding borrowers adversely impacted by COVID-19.