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Community Bank Compliance

Latest Compliance News

  • Court Delays Bureau’s Small-Dollar Rule

    Nov 09, 2018
    A federal court this week granted the Bureau of Consumer Financial Protection’s request to delay the effective date of its rule on small-dollar loans. The decision delays the August 2019 compliance date as the bureau plans to issue proposed rules in January that will reconsider the rule. The bureau plans to propose revisiting only the ability-to-repay provisions, which it said have greater consequences for consumers and the industry than the payment provisions.
  • Senators Seek Formal End to Choke Point Initiative

    Nov 08, 2018
    Republican members of the Senate Banking Committee called on the FDIC to send a message that the culture of Operation Choke Point is over. In a joint letter to Chairman Jelena McWilliams, the 13 senators said the agency should communicate with examiners, other FDIC officials, and financial institutions to ensure lawful businesses may continue operating without fear of politically motivated restrictions.
  • Regulators Press Sanctions Compliance

    Nov 06, 2018
    Federal banking regulators said compliance with sanctions imposed by the Treasury Department’s Office of Foreign Asset Control can impact information technology and other operations
  • Bureau Updates HMDA Compliance Guide

    Oct 31, 2018
    The Bureau of Consumer Financial Protection updated its Home Mortgage Disclosure Small Entity Compliance Guide. The updated guide reflects amendments from the Economic Growth, Regulatory Relief, and Consumer Protection Act as well as the corresponding interpretive and procedural rule.

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November 14 - November 16, 2018
November 16, 2018
BSA/AML Institute* - TX- SOLD OUT
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BSA/AML Institute* - MN
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05/15/18
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07/30/18
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November 27, 2018
Webinar: ACH & Wires 101: Understanding How They Function
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ACH & Wires 101: Understanding How They Function
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ICBA Members: $219
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Question of the Week

  • QUESTION: The bank has started marketing on social media. The bank wants to market deposit accounts. What must the bank be aware of when marketing on social media?

    ANSWER: 

    Advertising has been identified as having a high potential for UDAAP violations. Social media is no exception. The specific requirements for advertising under Regulation DD (and Regulation Z) do include requirements for electronic media (such as a website). Regulation DD defines advertisement to include any medium, and does provide an exemption for social media from the requirements. UDAAP exam procedures include social media advertisements. The bank must be aware of and address the compliance requirements to ensure that that products are advertised properly and do no mislead or deceive consumers.

    508 compliance should also be considered. Ensure that the bank includes contact information, as applicable, a telephone number and/or website. For social media advertisement, ensure that any disclosures, hyperlinks, etc., provide proper access to disclosures (for example, nothing is obscured by a link or popup), and that terms and conditions stated are in proximity to related items. If the bank is using a third party for social media – ensure that the bank knows what information is collected, it could be a fair lending issues especially if credit is involved.

    Reference: Regulation DD 1030.2; 1030.8; Regulation Z 1026.16; 102.24. CFPB TISA exam procedures October 2012, page 25. CFPB UDAAP Exam Procedures, October 2012.