CFPB Cracks Down on Credit Cards Marketed at Colleges

College Banking and Credit Card Agreements - The CFPB published a report on terms and fees associated with banking products marketed in partnership with colleges to students. The report raises questions about whether some marketing deals between colleges and financial institutions comply with Department of Education rules. The report also highlights a lack of transparency in the arrangements schools have made with financial institutions. In conjunction with the release of this report, the Department of Education issued guidance to schools on requirements for college-sponsored banking arrangements and committed to additional oversight on this issue. One of the reports key findings is that financial services providers and their partner schools appear to offer and promote more costly products to students than are otherwise available in the market.

From the Washington State DFI

From WA DFI

Mortgage Broker Practices Act Rulemaking – The DFI is proposing amendments to the Consumer Loan Act and the Mortgage Broker Practices Act to allows licensed mortgage loan originators to work from their residences without the company licensing the residence as a branch office. 

Inflation Adjustment Made for Reg Z Thresholds

Inflation Adjustments: Effective January 1, 2023, the exemption threshold for consumer credit transactions under Regulation Z increases from $61,000 to $66,400. The special appraisal requirements for higher-priced mortgage loans increases to $31,000, from $28,500. 

BSA Enforcement Action

$29 Million BSA Enforcement Action - The Financial Crimes Enforcement Network assessed a civil money penalty in the amount of $29,280,829.20 against Bittrex, for violations of the Bank Secrecy Act (BSA) and FinCEN’s implementing regulations. FinCEN’s action is part of a global settlement with the Office of Foreign Assets Control (OFAC). FinCEN’s investigation found that, from February 2014 through December 2018, Bittrex failed to maintain an effective AML program. Bittrex’s program failed to appropriately address the risks associated with the products and services it offered, including anonymity-enhanced cryptocurrencies. Reportedly Bittrex failed to implement effective transaction monitoring on its trading platform, relying on as few as two employees with minimal anti-money laundering training and experience to manually review all of the transactions for suspicious activity, which at times were over 20,000 per day.