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FinCEN and AGENCIES ISSUE CIP EXEMPTION FOR PREMIUM FINANCE LENDING

Posted by rcooper on  October 2, 2018
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Category: AML, BSA
On September 28, 2018, the Federal Reserve Board, Federal Deposit Insurance Corporation, National Credit Union Administration, and Office of the Comptroller of the Currency (Federal Banking Agencies or FBAs), in conjunction with FinCEN, announced an order exempting premium finance loans, made by banks to commercial customers, from the Customer Identification Program (CIP) requirements implementing section 326 of the USA Patriot Act (31 U.S.C. § 5318(l)). This is in line with FinCEN’s earlier exemption of these

TEN NEW AREAS IDENTIFIED AS HIGH INTENSITY DRUG TRAFFICKING AREAS

Posted by rcooper on  September 27, 2018
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Category: AML, BSA
On September 24, 2018, the Office of National Drug Control Policy designated ten new areas across Kentucky, New Jersey, North Carolina, Ohio, Pennsylvania, South Carolina, and West Virginia as High Intensity Drug Trafficking Areas (HIDTAs). The High Intensity Drug Trafficking Areas (HIDTAs) program, which was established with the enactment of the Anti-Drug Abuse Act of 1988, provides assistance to Federal, state, local, and tribal law enforcement agencies operating in areas determined to be critical drug-trafficking

NATIVE AMERICAN DISCRIMINATION

Posted by jholzknecht on  September 24, 2018
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Recently the U.S. Department of Housing and Urban Development (HUD) approved a Conciliation Agreement resolving claims brought by three homeowners, a couple and an individual, against loanDepot.com, LLC, and Appraisal Management Services of America, Inc. The three alleged that the lender refused to refinance their homes because they are on Native American lands. The individual also claimed that loanDepot.com would not refinance his house because he is Native American. The Fair Housing Act prohibits housing

CREDIT FREEZES AND OTHER CREDIT REPORT ISSUES

Posted by jholzknecht on  September 13, 2018
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Category: EGRRCPA
Section 301 of the Economic Growth, Regulatory Relief and Consumer Protection Act (EGRRCPA): Requires free placement and removal of security freezes by establishing a public webpage with links to credit reporting agency security freeze web pages. Requires Equifax, Experian and TransUnion to each set up a webpage for requesting fraud alerts and credit freezes. Provides additional ID theft protections to minors. Requires the big three credit bureaus to offer free electronic credit monitoring services to

FinCEN PROVIDES RELIEF FROM BENEFICIAL OWNERSHIP RULES FOR ROLLOVERS AND RENEWALS

Posted by rcooper on  September 11, 2018
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On Friday, September 7, 2018, the Financial Crimes Enforcement Network (FinCEN) issued a ruling which grants certain exceptions for financial institutions from the Beneficial Ownership Rule. Specifically the ruling provides financial institutions relief from the obligations under the Beneficial Ownership Requirements of identifying Legal Entity Customers in the case of: •A rollover of a certificate of deposit (CD) •A renewal, modification, or extension of a loan (e.g., setting a later payoff date) that does not
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