Compliance Action, Volume 27, Number 3

CFPB
CFPB Advisory Opinion on Permissible Purpose under FCRA (3 Action Steps)

By Nancy Castiglione, CRCM

The Consumer Financial Protection Bureau (CFPB) has issued an Advisory Opinion on permissible purpose requirements for furnishing, using, and obtaining consumer reports under the FCRA.

Compliance Notes

• FRS Finance and Economics Discussion Paper on CRA Credit for Loan Purchases
• FDIC Notice and Request for Comment Information Collection HMDA
• Bureau Issues Circular on Adverse Action Notices in Relation to Credit Decisions Based on Complex Algorithms

Disclosures/Forms
Limited English Proficiency (2 Action Steps)

By Nancy Castiglione, CRCM

While regulators are encouraging financial institutions to expand access to products and services to LEP consumers by offering a non-English language option on applications, make sure you consider all the servicing implications that will be affected by that decision.

Regulation
Customer Due Diligence (2 Action Steps)

By Nancy Castiglione, CRCM

Banking regulators have issued a joint Statement on the Risk-Based Approach to Assessing Customer Relationships and Conducting Customer Due Diligence (CDD) that also reminds institutions they should be using a risk-based approach to their BSA/AML CDD responsibilities.

Compliance Calendar

Editorial
Consumer Access to Information or Complaints?

By Nancy Castiglione, CRCM

The basis for the CFPB's recent RFI regarding Relationship Banking and Customer Service appears to be misdirected.

Flood Insurance Q&As

By Nancy Castiglione, CRCM

Federal regulators have issued issued Flood Q&As to provide clarification and enhancement to existing guidance.

Compliance Online
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