Archive

  This week’s headlining news item is the latest on CRA Modernization. A joint press release from the FDIC, OCC, and FRB issued today announced that due to pending litigation, they intend to rescind the Community Reinvestment Act final rule issued October 2023 and reinstate the framework that existed prior to its release. We’ll be closely watching how the agencies approach CRA implementation and will be sure to share insights and updates with you here. […]

On Friday March 21st, FinCEN issued an interim final rule that removes the requirement for U.S. companies and U.S. persons to report beneficial ownership information (BOI) to FinCEN under the Corporate Transparency Act. In the interim final rule, FinCEN revises the definition of “reporting company” in its implementing regulations to mean only those entities that are formed under the law of a foreign country and that have registered to do business in any U.S. State or […]

Despite the increasing adoption of digital payments, check fraud remains a significant challenge for financial institutions. According to FinCEN, check fraud losses in the U.S. totaled $21 billion in 2023, representing nearly 80% of global check fraud losses. The FTC reported that check fraud was high on the list of frauds that cost consumers over $10 billion in 2023. The persistent threat of check fraud has far-reaching consequences for the banking industry. Financial institutions face […]

As you’re probably already aware, FinCEN issued the Beneficial Ownership Information Access and Safeguards Rule (Access Rule) on December 22, 2023. This rule implements portions of the Corporate Transparency Act (CTA) and authorizes certain persons access to information reported to FinCEN regarding reporting companies, beneficial owners, and company applicants (BOI). On February 20, 2024, the effective date of the Access Rule, FinCEN published a Small Entity Compliance Guide for Beneficial Ownership Information Access and Safeguards […]

Last week FinCEN held it’s annual Law Enforcement Awards Program ,which recognizes cases that have been successfully prosecuted using reports provided financial institutions, and emphasized how BSA reporting really does make a difference. The stories are always interesting but I think they also serve as a reminder to our teams that the work they do is important and has a real impact. And for many, this might be a much-needed reminder. Often, there is no […]