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FINCEN ISSUES AN ANPRM FOR BSA RULES FOR REAL ESTATE TRANSACTIONS

Posted by jholzknecht on  December 6, 2021
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Category: BSA, FinCEN
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On December 6, 2021, the Financial Crimes Enforcement Network (FinCEN) published an Advance Notice of Proposed Rulemaking (“ANPRM”) to solicit public comment on a potential rule to address the vulnerability of the U.S. real estate market to money laundering and other illicit activity. FinCEN said the systemic money laundering vulnerabilities presented by the U.S. real estate sector, and consequently, the ability of illicit actors to launder criminal proceeds through the purchase of real estate, threatens U.S. national

FLOOD INSURANCE CONTINUATION

Posted by jholzknecht on  December 3, 2021
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Category: Flood Insurance
On December 3, 2021, Congress reauthorized the National Flood Insurance Program (NFIP) through February 18, 2022.  Prior to this most recent temporary reauthorization, the NFIP had been set to expire on December 3, 2021. Since 2017, there have been 18 temporary reauthorizations as more comprehensive and permanent legislative solutions to the program have failed to gain traction in Congress.

CFPB CRITICAL OF CREDIT BUREAU PROCEDURES

Posted by jholzknecht on  December 2, 2021
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On November 4, 2021, the Consumer Financial Protection Bureau published a sixteen-page advisory opinion to highlight that a consumer reporting agency that uses inadequate matching procedures to match information to consumers, including name-only matching (i.e., matching information to the particular consumer who is the subject of a consumer report based solely on whether the consumer’s first and last names are identical or similar to the names associated with the information), in preparing consumer reports (for

FFIEC UPDATES BSA MANUAL

Posted by jholzknecht on  December 1, 2021
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Category: AML, BSA, FFIEC
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On December 1, 2021, the Federal Financial Institutions Examination Council (FFIEC) released one new section and updates to three sections of the Bank Secrecy Act/Anti-Money Laundering (BSA/AML) Examination Manual. Today’s updates affect the following sections: Introduction – Customers (new) Charities and Nonprofit Organizations Independent Automated Teller Machine Owners or Operators Politically Exposed Persons The updates should not be interpreted as new requirements or as a new or increased focus on certain areas. Rather, these sections provide

FHFA 2022 CONFORMING LOAN LIMITS

Posted by jholzknecht on  November 30, 2021
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On November 30, 2021, the Federal Housing Finance Agency (FHFA) announced the conforming loan limits (CLLs) for mortgages to be acquired by Fannie Mae and Freddie Mac (the Enterprises) in 2022. In most of the U.S., the 2022 limit for one-unit properties will be $647,200, an increase of $98,950 from $548,250 in 2021. National Baseline The Housing and Economic Recovery Act (HERA) requires that the baseline CLL for the Enterprises be adjusted each year to reflect
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