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Legal Briefs

February 23, 2012

Consumer Financial Protection Bureau (CFPB)

The CFPB announced a proposed rule to include debt collectors and consumer reporting agencies under its nonbank supervision program. This would mean that debt collectors and credit reporting agencies that qualify as larger participants would be subject to the same supervision process that the CFPB applies to banks. Comments are due within 60 days of the proposed rule being published in the Federal Register.

The CFPB convenes a small-business panel  for Know Before You Owe mortgage disclosures. The review panel will solicit feedback from small businesses that make mortgage loans and conduct mortgage closings.

The CFPB has also announced the launch of an inquiry into overdraft practices. The inquiry will be looking at how overdraft practices impact consumers and request input on a proposed ‘penalty fee box’ for periodic statements. The main areas the inquiry will focus on are:

  1. Transaction re-ordering that increases consumer costs;
  2. Missing or confusing information;
  3. Misleading marketing materials; and
  4. Disproportionate impact on low-income and young consumers.

Office of Foreign Assets Control (OFAC)

The OFAC SDN list was updated again. Last update: Feb. 16, 2012.

Financial Crimes Enforcement Network (FinCEN)

FinCEN has announced the release of the test site for the new currency transaction report (CTR) and suspicious activity report (SAR) filings. The test website will allow for testing of batch and computer-to-computer filings of FinCEN’s new CTR and SAR.

FinCEN has also released guidance to financial institutions on providing financial services to foreign-located money service businesses (MSBs). The guidance advises financial institutions of their obligations under the Bank Secrecy Act (BSA) when providing financial services to foreign-located MSBs.

Questions? Contact the Compliance Hotline: 1.800.546.4465, compliance@nwcua.org.

Posted on 02/22/2012

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