Weekly Rewind...News from Your Regulators

OFAC Publishes Payment Systems Guidance


Sanctions Compliance Guidance for Instant Payment Systems - OFAC published the Sanctions Compliance Guidance for Instant Payment Systems, which emphasizes the importance of taking a risk-based approach to managing sanctions risks in the context of new payment technologies such as instant payment systems and to highlight considerations relevant to managing those risks.


FFIEC Cybersecurity Guide Updated


Updated Cybersecurity Resource Guide – The FFIEC updated its Guide for financial Institutions. The FFIEC states that the purpose of the guide is to help financial institutions meet their security control objectives and prepare to respond to cyber incidents. The updates include ransomware-specific resources to address the recent ransomware incidents. 


Risks of Crypto-Asset Activities


Digital Asset Financial Stability Risks and Regulation Report – The Financial Stability Oversight Council issued a report stating that crypto-asset activities could pose risks to the stability of the U.S. financial system, and emphasized the importance of appropriate regulation. 


From NCUA

Defending Against Ransomware Attacks – The NCUA, along with the FBI, Treasury Department, and the Wisconsin DFI, is holding a webinar on October 13, Ransomware in the Financial Sector. All of the webinar presentations will have real world examples to illustrate the potential impact of ransomware attacks.


From the CFPB Blog

Reconsideration of Value – A recent CFPB blog reminds lenders of the need to offer a reconsideration of a home valuation that the consumer believes to be inaccurate. A lender’s reconsideration of value process must ensure that all borrowers have an opportunity to explain why they believe that a valuation is inaccurate and the benefit of a reconsideration to determine whether an adjustment is appropriate. While an individual lender’s reconsideration of valuation process may vary, lenders must make sure that their reconsideration of value process is nondiscriminatory and available and accessible to all. 


From the Federal Reserve

Final Debit Card Network Rule – The Fed issued amendments to Regulation II, effective July 2023. Under the final rule, institutions must configure each of its debit cards so that card-not-present transactions performed with those cards can be processed on at least two unaffiliated networks. As a practical matter, institutions will first need to determine whether card-not-present transactions performed with its debit cards can already be processed on at least two unaffiliated networks. If the institution is not already compliant with the final rule, it will need to adjust its debit card processing arrangements to meet the final rule’s requirements. 


CFPB Issues Remittance Transfer Penalties

Remittance Transfer Compliance Failure Penalties - The CFPB is taking action against Choice Money Transfer for multiple violations of the Remittance Transfer Rule and the Electronic Fund Transfer Act. The CFPB found the company did not accurately disclose important prepayment information to remittance senders, such as money transfer fees, current exchange rates and the date the recipient would receive the funds. The company also had deficient recordkeeping practices that made it difficult for consumers to dispute erroneous transactions and receive a refund of certain fees. The CFPB is ordering Choice Money to pay a $950,000 penalty that will be deposited into the CFPB’s victims’ relief fund.

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