OCC Assesses a $15 Million Civil Money Penalty for Governance and Oversight of Third-Party Affiliate
Today, the Office of the Comptroller of the Currency (OCC) announced a $15 million civil money penalty against American Express National Bank (American Express). The penalty is a result of American Express failing to govern and oversee a third-party affiliate and for violations of regulations relating to certain efforts to retain small business customers. This is the first CMP issued since the agencies released their interagency guidance on June, 9th. The OCC found that American
CFPB Responds to the TBA, ABA, and Rio Banks’ Lawsuit
Category: CFPB, ECOA, Small Business Data Collection and Reporting
On May 4, 2023, Compliance Resource blogged on the lawsuit challenging Section 1071 final rule, released by the CFPB in March of this year. The CFPB filed an opposition to the lawsuit in June claiming the plaintiffs have not established their standing for relief or that venue is proper in the Southern District of Texas because: Rio Bank alleged in the complaint that it made 409 small business and agricultural loans in 2022, per the
On June 28, 2023, the CFPB released a set of Frequently Asked Questions to address for determining institutional coverage focused on areas like: Financial Institution Coverage Metropolitan Statistical Areas (MSA) Types of transactions Ag purpose credit Refinancings Temporary loans What to do if you did not collect Gross Annual Revenue for 2022 and 2023 Covered Credit Transactions and Small Businesses Covered credit transactions What is a small business Individuals and sole proprietorship The purpose of
If your institution is still questioning which compliance tier you fall into for Small Business Data Reporting, Section 1071. If you have questions about covered transactions or just want to hear what the CFPB has to say on 1071 coverage. You’re in luck. The CFPB announced this morning that they will host a RegCast on the small business lending rule. It will provide information from the rule to help financial institutions determine whether they are
With the introduction of Section 1071’s final rule earlier this year and the anticipation of the interagency update to CRA, compliance departments across the country are grappling with the regulatory frameworks that support fair lending and consumer protection. Here’s an overview of how these three components, Section 1071, CRA, and Fair Lending, relate to each other: Section 1071 Data Collection Through the collection and reporting of data related to lending practices, specifically for small businesses
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