In honor of National Compliance Officer Day, Kimberly Boatwright has turned a familiar compliance exercise on its head: What happens when the person conducting the risk assessment is also the subject of it? The assessment below is entirely unofficial and written in good fun, but if the findings about crowded calendars, caffeine, and “just one more project” feel familiar, you’re probably in the right profession. ______________ The Compliance Officer Risk Assessment A Completely Unofficial Self-Assessment […]
Category: Compliance Management
Sharpen the Saw — Train Through the Uncertainty
In the wake of shifting political winds and a dramatic change in regulatory tone from the Trump Administration, compliance officers across the country are rightfully asking: What now? The agencies have indicated that they plan to rescind proposed changes to the Community Reinvestment Act (CRA). Section 1071’s future is uncertain. And many long-anticipated regulations are stalled or suddenly up for reconsideration. The message from Washington seems to be: “We’re rethinking things.” And that leaves many […]
UDAAP IS THE FOCUS OF THE CFPB’S SUPERVISORY HIGHLIGHTS SUMMER EDITION
Today, the Consumer Financial Protection Bureau (CFPB) released its 36-page Summer edition of Supervisory Highlights report which focuses on unfair, deceptive, and abusive acts or practices across many consumers financial products. The latest edition of the Supervisory Highlights report covers findings from CFPB supervisory examinations completed from July 2022 to March 2023. CFPB Director Rohit Chopra stated that “Today’s report furthers our efforts to highlight conduct that violates federal law, including the prohibition on abusive […]
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 Released FAQs for Small Business Data Collection and Reporting
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 […]