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PRIVACY PROVISIONS FINALLY FINALIZED

Posted by jholzknecht on  August 13, 2018
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Category: CFPB, Privacy, Regulation P
On August 10, 2018 the Bureau of Consumer Financial Protection (CFPB) completed the nearly three year process of issuing relatively minor amendments to implement legislation that allows financial institutions that meet certain requirements to be exempt from sending annual privacy notices to their customers. The Gramm-Leach-Bliley Act (GLBA) generally requires that financial institutions send annual privacy notices to customers. In December 2015, Congress amended the GLBA as part of the Fixing America’s Surface Transportation Act

EXTENSION OF LIMITED EXCEPTION TO BENEFICIAL OWNERSHIP RULE

Posted by jholzknecht on  August 9, 2018
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On August 8, 2018 Financial Crimes Enforcement Network (FinCEN) announced a 30-day extension to the limited exception to the Beneficial Ownership Rule   On May 16, 2018, FinCEN issued a 90-day limited exceptive relief to covered financial institutions from the obligations of the Beneficial Ownership Rule for Legal Entity Customers (Beneficial Ownership Rule) for certain financial products and services (i.e., certificate of deposit or loan accounts) that were established before the Beneficial Ownership Rule’s Applicability

FLOOD INSURANCE – CONGRESS CONTINUES TO PLAY GAMES

Posted by jholzknecht on  August 2, 2018
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Category: Flood Insurance
On July 31, 2018 President Trump signed S. 1182, the “National Flood Insurance Program Extension Act of 2018,” which reauthorizes the Federal Emergency Management Agency to enter into new contracts for flood insurance and borrow from the Treasury up to specified amounts through November 30, 2018. The House Amendment to S. 1182 extends the National Flood Insurance Program, which was set to expire July 31, 2018, through November 30, 2018. This amendment does not include

SAR- E-FILING SYSTEM CHANGES

Posted by jholzknecht on  July 31, 2018
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As promised earlier this month on July 27th, 2018, FinCEN released the following changes to the BSA E-Filing System production environment: FinCEN posted the new discrete entry form version (v1.2) of the FinCEN Suspicious Activity Report (SAR) for download/submission; FinCEN began accepting batch files containing the new FinCEN SAR in the new FinCEN 2.0 XML schema format; FinCEN updated the FinCEN CTR XML batch schema to prohibit certain unwanted characters/formatting for all elements values in

UDAP VIOLATIONS ON ADD-ON DEPOSIT ACCOUNT PRODUCTS

Posted by jholzknecht on  July 27, 2018
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On July 26, 2018 the Federal Reserve Board issued a consent order against Community Trust Bank, Inc. of Pikeville, Kentucky, for unfair and deceptive practices, requiring the bank to pay approximately $4.75 million in restitution to approximately 11,000 consumers and make certain consumer compliance enhancements. The practices were in effect from 1997 to present. It appears that the bank violated section 5 of the Federal Trade Commission Act in its offering of deposit account add-on
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