Interagency Flood Webinar

Flood Insurance Webinar – On July 27, the FDIC, along with the FRS, NCUA, and OCC, will host a Q&A webinar on the 2022 updates to the Interagency Questions and Answers Regarding Flood Insurance.

CFPB Takes Action on Debt Collectors

Advisory Opinion - Debt Collectors - The CFPB issued an advisory opinion to affirm that the Fair Debt Collection Practices Act and Regulation F prohibit debt collectors from charging consumers pay-to-pay fees (also known as convenience fees) for making payment a particular way, such as by telephone or online, unless those fees are expressly authorized by the underlying agreement or are affirmatively permitted by law.

Credit Reporting Act & State Laws – The CFPB issued an Interpretive Rule which affirms states’ abilities to protect their residents through their own fair credit reporting laws. With limited preemption exceptions, states have the flexibility to preserve fair and competitive credit reporting markets by enacting state-level laws that are stricter than the federal Fair Credit Reporting Act (FCRA).

NCUA Issues Enforcement Actions

Enforcement Actions – The NCUA banned two former employees. In one case, a former accounting manager deposited checks intended for the credit union into her personal accounts, created fictitious journal entries and supporting document, and falsified the credit union’s records. The credit union reported a loss of approximately $437,000. It is reported that she also embezzled $384,000 from her previous job. In the second case, an ex-employee misappropriated member funds of approximately $32,130 by posting fictitious check deposits to her own account, and using other employees’ credentials to reverse or waive fees that had been assess on her accounts. 

From the Federal Reserve

Distressed or Underserved Nonmetropolitan Middle-Income Geographies – Along with the FDIC, and OCC, the Federal Reserve published the 2022 list of distressed or underserved nonmetropolitan middle-income geographies. These are geographic areas where revitalization or stabilization activities are eligible to receive Community Reinvestment Act (CRA) consideration pursuant to the definition of community development under the agencies' regulations.

From the FinCEN –

Increased Vigilance for Potential Russian and Belarusian Export Control Evasion Attempts - The Financial Crimes Enforcement Network and the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) issued a joint alert to financial institutions advising them to be vigilant against efforts by individuals or entities to evade BIS export controls implemented in connection with the Russian Federation’s further invasion of Ukraine. The alert provides financial institutions with an overview of BIS’s export restrictions to date, a list of certain commodities of concern, and other information they can use and incorporate into their risk-based screening of financial transactions. In addition, it provides select transactional and behavioral red flag indicators of export control evasion, including red flags derived from recent Bank Secrecy Act reporting.