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OCC Takes Action Against TD Bank for BSA/AML Deficiencies

Yesterday, The Office of the Comptroller of the Currency (OCC) issued a cease and desist order against TD Bank, N.A. and TD Bank USA, N.A., and imposed a substantial $450 million civil money penalty due to significant deficiencies in the bank’s compliance with the Bank Secrecy Act (BSA) and anti-money laundering (AML) regulations. In addition to the monetary penalty, the OCC has restricted the bank’s growth and mandated that it allocate resources to rectify its […]

Federal Regulators Extend Comment Period For RFI on Bank-Fintech Partnerships

On September 13, 2024, Federal regulators (FDIC, OCC, FBR) announced an extension of the comment period for its Request for Information (RFI) concerning partnerships between banks and financial technology (fintech) companies. Originally set to close at the end of  September 2024, the new deadline is now October 30, 2024. Key Highlights of the Announcement Purpose of the RFI: The regulators aim to gather insights on the evolving landscape of bank-fintech partnerships, particularly regarding how these […]

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 […]

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, […]

2023 HMDA GUIDE

The federal bank regulatory agencies are announcing the Federal Financial Institutions Examination Council’s (FFIEC) revised “A Guide to HMDA Reporting: Getting It Right!” (2023 guide). The 2023 guide provides resources to help banks1 comply with the Home Mortgage Disclosure Act (HMDA) and Regulation C, its implementing regulation (12 CFR 1003). The 2023 guide reflects a technical amendment to the 2020 HMDA rule to adjust the loan volume thresholds effective January 1, 2023,2 for reporting HMDA data on […]