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 […]

CFPB – RegCast Announced for July 25, 2023

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 […]

Interagency Requirements for Third-Party Management Are Finalized

On June 6, 2023, final interagency guidance was issued on managing risks associated with third-party relationships. The guidance provides sound principles that supports a risk-based approach to third-party risk management. It is important that financial institutions include these practices when developing and implementing risk management practices for all stages in the life cycle of third-party relationships. Key Components: Promotes consistency in the agencies’ supervisory approach to third-party risk management. The guidance replaces the Agencies’ existing, […]