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Community Bank Compliance

Latest Compliance News

  • CFPB Hosting 1071 Symposium Next Month

    Oct 25, 2019
    The Consumer Financial Protection Bureau said it will hold a symposium early next month on Section 1071 of the Dodd-Frank Act, which requires the CFPB to implement rules for the collection and reporting of data on financial institutions’ small-business lending.
  • House Passes ‘Beneficial Owner’ Reform

    Oct 23, 2019
    The House voted 249-173 to pass ICBA-advocated legislation providing relief from "beneficial ownership" disclosure mandates.
  • CFPB Extends Temporary HMDA Relief

    Oct 15, 2019
    The Consumer Financial Protection Bureau issued a final rule extending for two years Home Mortgage Disclosure Act temporary reporting thresholds for open-end lines of credit.
  • Agencies Issue BSA Statement on Digital Assets

    Oct 15, 2019
    Federal agencies reminded individuals who engage in activities involving digital assets of their obligations under the Bank Secrecy Act.

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Upcoming Events

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Feb
23
February 23 - February 28, 2020
February 28, 2020
Compliance Institute* - TX
Event Type: Seminar/Institutes
Operations, Lending, Lending, Featured on Homepage, Deposit/Operations/Payments, Compliance Certification, Compliance
Dallas, TX
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May
04
May 04 - May 06, 2020
May 06, 2020
BSA/AML Institute* - MN
Event Type: Seminar/Institutes
Executive C-Suite Training, Compliance, BSA Certification
Minneapolis, MN

Question of the Week

  • QUESTION: Does error resolution apply to a prepaid account for which the consumer identification and verification process is not completed?

    ANSWER:

    The Regulation E final rule extends Regulation E’s limited liability and error resolution requirements to all prepaid accounts. However, Regulation E is specific with regard to provisional credit for errors. From Regulation E 1005.18(e)(3):

    A prepaid account (other than a payroll card account or government benefit account) is not subject to the limited liability and error resolution requirements if the bank has not completed successfully its customer identification and verification process for a prepaid account.

    Once the bank successfully completes the customer identification and verification process, the bank must limit the consumer’s liability for unauthorized EFTs and resolve errors that occur after verification according the prepaid rule requirements.

    Reference: Regulation E: 12 CFR 1005.18(e)(3); 1005.6 and 1005.11. Final Rule for Regulation E: Federal Register November 22, 2016, page 83935. See also: CFPB Prepaid Rule, Small Entity Compliance Guide, March 2018, pages 112 and 113.