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The Treasury Department has reported that OFAC yesterday sanctioned four individuals affiliated with La Nueva Familia Michoacana (LNFM), a Mexican cartel designated as a Foreign Terrorist Organization and a Specially Designated Global Terrorist, that has poisoned Americans by trafficking fentanyl and other illicit drugs into the United States. LNFM’s crimes also include the smuggling of illegal aliens into the United States and violence against its rivals and Mexican security forces, utilizing drones and bombs in addition to conventional firearms. Those sanctioned today, all of whom are siblings, include the group’s notorious co-leaders: Johnny Hurtado Olascoaga and Jose Alfredo Hurtado Olascoaga.

For a link to identification information on the designated parties, see yesterday’s BankersOnline OFAC Update.

PYMNTS has reported that Bank of America has been ordered to pay $540.3 million following a judge's ruling in a lawsuit in which the FDIC accused the bank of paying less than it owed for deposit insurance. In a decision made public on Monday, U.S. District Judge Loren AliKhan in Washington, D.C., said the payment covers assessments from the second quarter of 2013 through the end of 2014, plus interest.

The FDIC sued Charlotte, North Carolina-based Bank of America for $1.12 billion in 2017, accusing it of reducing its deposit insurance contributions by failing to honor a 2011 rule that changed how banks report risk exposure to counterparties. That rule was one of many federal reforms designed to ensure the stability of the banking system, and avert a repeat of the 2008 global financial crisis. But the judge ruled that the FDIC had waited too long to sue over claims predating the second quarter of 2013.

Our monthly review of the Federal Reserve Board's archive of Community Reinvestment Act evaluations has determined that the Reserve Banks publicly released 19 evaluations in March 2025. Sixteen of those evaluations received a Satisfactory rating.

We offer our congratulations to these three banks, whose evaluations received Outstanding ratings:

• East West Bank, Pasadena, California
• The Genoa Banking Company, Genoa, Ohio
• Green Dot Bank, Provo, Utah

Links are to the banks' evaluations.

The FDIC, Federal Reserve Board, NCUA, and OCC have jointly announced they have temporarily paused certain appraisal requirements for real estate-related transactions, to help facilitate recovery efforts from wildfires and straight-line wind damage in Los Angeles County, California, this year, .

The agencies' action is expected to allow banks and credit unions to work with families and businesses without obtaining an appraisal. Banks and credit unions will still be required to determine that the value of the real estate supports the institution's decision to enter into the transaction.

The pause should make financial institutions better able to lend or modify loans in areas where wildfire and straight-line wind damage has made appraisals challenging to obtain. This action is also expected to reduce loan processing times, helping to facilitate recovery from the disaster.

The temporary pause order will be effective upon its publication in the Federal Register. It will expire on January 8, 2028, three years after the president declared the relevant area a major disaster. The agencies will monitor institutions' real estate lending practices to ensure that transactions are being conducted in a safe and sound manner.

• OCC Bulletin 2025-7, "Real Estate Appraisals: Temporary Exceptions to Appraisal Requirements in Areas Affected by Los Angeles County, California, Wildfires and Straight-Line Winds"
• FDIC FIL-10-2025, "FDIC Issues Temporary Exceptions to Appraisal Requirements in Los Angeles County as Affected by California Wildfires and Straight-line Winds"

FDIC FIL-9-2025 was issued yesterday to announce the FDIC is making permanent the establishment of electronic communications as the preferred method for supervisory correspondence. This makes permanent the alternative secure mail procedures that were initially implemented on a temporary basis in March 2020.

Attached Supervisor Correspondence Procedures provide guidance on how to send official correspondence related to supervisory matters to the FDIC using the FDIC's Secure Email portal. The FDIC will use the portal to send outgoing mail for official supervisory correspondence. If electronic communications are not available financial institutions can continue to submit correspondence in hardcopy format, but use of hardcopy documents is expected to be rare.

The Federal Reserve Board has released the minutes of the Board's discount rate meetings on February 18, March 10, and March 19, 2025.

The OCC has publicly released a letter sent to its supervised institutions regarding unauthorized access to OCC email systems. The OCC provided public notice of the unauthorized access and its designation as a major information security incident on April 8, 2025.

The OCC said it will inform each regulated institution if it determines the unauthorized user accessed information specific to that institution for their awareness. The OCC also will provide all supervised institutions with email user domains that were included in the compromised information so they may determine what information or data they may have sent to OCC users during the timeframe of the unauthorized access.

The New York State Department of Financial Services (DFS) has announced that Block, Inc. will pay a $40 million penalty for significant failures in its Bank Secrecy Act/Anti-Money Laundering compliance program, which violated DFS money transmitter and virtual currency regulations. In addition to the monetary penalty, Block is required to retain an independent monitor to perform a comprehensive evaluation of its compliance with the Department’s regulations and its remediation efforts.

DFS Superintendent Adrienne A. Harris said, "The rapid growth of Block’s Cash App absent a robust compliance function created risk and vulnerabilities that violated the rules financial services companies operating in New York must adhere to. The Department is taking decisive steps to ensure accountability, including the appointment of an independent monitor to oversee corrective measures.”

Block owns and operates Cash App, a peer-to-peer money transmission service that allows users to send and receive fiat currency. The company has been licensed by the Department to conduct money transmission business in the State of New York since 2013, and virtual currency business through Cash App since 2018.

For more information and a link to the DFS Consent Order, see "Block, Inc. to pay $40M for failures in BSA/AML program," in the BankersOnline Penalty pages.

The CFPB, on April 7, 2025, filed with the U.S. District Court for the Southern District of New York a Consent Motion to withdraw as a plaintiff in a case filed jointly in 2022 with the Attorney General of the State of New York against MoneyGram International, Inc. and MoneyGram Payment Systems, Inc. In that case, the CFPB and the State of New York alleged that MoneyGram violated Regulation E and the Remittance Transfer Rule, which implement the Electronic Fund Transfer Act, and the Consumer Financial Protection Act.

The Bureau's withdrawal leaves the People of the State of New York as the sole plaintiffs in the suit.

Yesterday, Federal Reserve Board Governor Christopher J. Waller spoke at the Certified Financial Analysts Society of St. Louis, St. Louis, Missouri, on "A Tale of Two Outlooks," discussing his outlook for the U.S. economy and the implications for monetary policy following recent announcements on tariffs to be imposed by the current Administration. He described tariffs as "the elephant in the room," to be talked about.

FinCEN has announced the renewal of its Geographic Targeting Orders (GTOs) that require U.S. title insurance companies to identify the natural persons behind shell companies used in non-financed purchases of residential real estate. FinCEN said the terms of the GTOs are effective beginning April 15, 2025, and ending on October 9, 2025, and that the GTOs continue to provide valuable data on the purchase of residential real estate by persons possibly involved in various illicit enterprises. Renewing the GTOs will further assist in tracking illicit funds and other criminal or illicit activity.

FinCEN renewed the GTOs that cover certain counties and major U.S. metropolitan areas in California, Colorado, Connecticut, Florida, Hawaii, Illinois, Maryland, Massachusetts, Nevada, New York, Texas, Washington, Virginia, and the District of Columbia. No changes have been made to jurisdictional coverage since the last issuance of these GTOs. The purchase price threshold likewise remains $300,000 for each covered metropolitan area, with the exception of the City and County of Baltimore, where the purchase price threshold is $50,000.

• FAQs on the GTOs

The ABA Banking Journal has reported that the CFPB has reached an agreement with the American Bankers Association and others to settle a lawsuit over its 2024 rule on credit card late fees.

Last year, the CFPB issued a final rule to lower the safe harbor dollar amount for late fees to $8, eliminate a higher safe harbor dollar amount for late fees for subsequent violations of the same type, and eliminate the annual inflation adjustment for the safe harbor amount that was provided by the Federal Reserve in 2010. A suit was brought by the ABA, the U.S. Chamber of Commerce, and others asserting that the CFPB exceeded its statutory authority in issuing the rule. Under the terms of a settlement, the Bureau acknowledged the allegations, and the parties have asked the court to vacate the rule.

On April 15, the ABA Banking Journal reported that the court has vacated the rule.

The Financial Stability Board has announced it has published its finalized Format for Incident Reporting Exchange (FIRE), a global initiative aimed at streamlining cyber and operational incident reporting. By introducing a standardized format, FIRE addresses the fragmentation in reporting requirements, alleviating the burden on firms that operate across multiple jurisdictions.

FIRE encompasses a wide range of operational and cyber incidents. Its potential applicability extends to third-party service providers and firms beyond the financial sector. Its focus on promoting convergence and flexibility in incident reporting has garnered strong support, underscoring its practical value and relevance to stakeholders.

• Final report

Republican lawmakers in the House and Senate have introduced a joint resolution of disapproval under the Congressional Review Act to overturn a 2024 final rule that changed how the Office of the Comptroller of the Currency reviews proposed bank mergers, according to a press release from Congressman Andy Barr's office. .

The OCC last year adopted a rule that ended its practice of automatically approving merger applications on the 15th day after the close of the comment period unless the agency takes action to remove the filing for expedited processing. The rule also amended how the OCC considers financial stability, financial and managerial resources, future prospects, and convenience and needs factors.

If passed in both the House and the Senate and approved by the president, the resolution, introduced by Representative Barr (R-KY) and Senator John Kennedy (R-LA), would also prohibit the OCC from issuing merger regulations in the future without congressional authorization.

The CFPB on Friday announced that, with respect to the regulation titled "Registry of Nonbank Covered Persons Subject to Certain Agency and Court Orders," subpart B of 12 CFR part 1092, it will not prioritize enforcement or supervision actions with regard to entities that do not satisfy future deadlines under the regulation to submit registration information. This policy applies to, but is not limited to, the upcoming April 14, 2025 registration deadline for entities subject to 12 CFR 1092.206(a)(2) and July 14, 2025 registration deadline for entities subject to 12 CFR 1092.206(a)(3). The Bureau will instead continue to focus its enforcement and supervision activities on pressing threats to consumers.

The Bureau is further considering issuing a notice of proposed rulemaking to rescind the regulation or narrow its scope.

The Small Business Administration has announced several new verification measures within its loan application process to strengthen protections against fraud and ensure its programs only benefit eligible American small business owners. Key changes include:

• Citizenship Verification: All SBA loan applications now include a citizenship verification provision to ensure only legal, eligible applicants can access SBA programs. Lenders are required to confirm that applicant businesses are not owned in whole or in part by an illegal alien.
• Date of Birth Verification: All SBA loan applications now include a process to verify applicant age and date of birth. This provision will mitigate fraud stemming from applicants using an identity other than their own, including those of children or the deceased.
• Automatic Fraud Alerts: SBA’s date of birth verification process will automatically flag any applicant claiming to be younger than 18 or older than 115 years of age.

The Treasury Department has reported that OFAC has designated United Arab Emirates (UAE)-based Indian national Jugwinder Singh Brar (Brar), who owns multiple shipping companies that boast a fleet of nearly 30 vessels, many of which operate as part of Iran’s “shadow fleet.” OFAC is also designating two UAE- and two India-based entities that own and operate Brar’s vessels that have transported Iranian oil on behalf of the National Iranian Oil Company (NIOC) and the Iranian military.

According to Treasury, Brar’s vessels engage in high-risk ship-to-ship (STS) transfers of Iranian petroleum in waters off Iraq, Iran, the UAE, and the Gulf of Oman. These cargoes then reach other facilitators who blend the oil or fuel with products from other countries and falsify shipping documents to conceal links to Iran, allowing these cargoes to reach the international market.

Concurrently, the Department of State designated four companies for having knowingly engaged in a significant transaction for the purchase, acquisition, sale, transport, or marketing of petroleum or petroleum products from Iran, and identifying two vessels as blocked property of two of these companies.

For a link to identification information on the designated individuals, entities, and vessels, see yesterday’s BankersOnline OFAC Update.

The Federal Reserve Board has released the minutes of the Federal Open Market Committee meeting on March 18–19, 2025.

Yesterday, the House of Representatives passed a joint resolution to overturn the Consumer Financial Protection Bureau’s "Overdraft Lending: Very Large Financial Institutions" rule. The CFPB overdraft limit requires banks with at least $10 billion in assets to cap overdraft fees at $5 unless they voluntarily set a cap that covers their actual costs and losses or treat overdraft protection as a loan covered by the Truth in Lending Act.

The House also passed a joint resolution disapproving the rule submitted by the CFPB relating to "Defining Larger Participants of a Market for General-Use Digital Consumer Payment Applications."

The two joint resolutions now go to the president, who can approve or veto them. If he approves the resolutions, the CFPB rules will be nullified, and no substantially similar rules can be issued.

The Treasury Department has announced that OFAC has sanctioned Mexican national Jesus Alfredo Beltran Guzman, a key leader of the Beltran Leyva Organization (BLO), for playing a significant role in the trafficking of illicit drugs, including fentanyl, cocaine, heroin, and methamphetamine, into the United States.

Treasury also reported that OFAC has designated five entities and one individual based in Iran for their support to key entities that manage and oversee Iran’s nuclear program, including the Atomic Energy Organization of Iran and its subordinate Iran Centrifuge Technology Company.

For a link to identification information on the designated parties, see yesterday’s BankersOnline OFAC Update.

The Department of Housing and Urban Development has announced the Federal Housing Administration (FHA) is extending by an additional 90 days its existing foreclosure moratoriums on FHA-insured single family mortgages in the Presidentially-Declared Major Disaster Areas (PDMDAs) resulting from Hurricanes Helene and Milton. The extensions provide more time for impacted American families in devastated areas in Florida, Georgia, North Carolina, South Carolina, Tennessee, and Virginia to seek Federal, state, or local assistance and underscore HUD’s commitment to supporting Americans impacted by the hurricanes.

The FHA insures over one million single family mortgages in the Helene and Milton PDMDAs. The moratoriums prohibit mortgage servicers from initiating or completing foreclosure actions on FHA-insured single family forward or Home Equity Conversion mortgages in the Hurricane Helene and Milton PDMDAs through July 10, 2025. This is the second extension of the moratoriums, which were most recently set to expire on April 11, 2025.

Today, FinCEN issued a Financial Trend Analysis focused on patterns and trends identified in Bank Secrecy Act (BSA) data linked to fentanyl-related illicit finance. Between January and December 2024, financial institutions filed 1,246 BSA reports that identified suspected fentanyl-related activity amounting to approximately $1.4 billion in suspicious transactions. The reported financial activity highlighted various aspects of the illicit fentanyl supply chain—including precursor chemical procurement, fentanyl trafficking, and fentanyl-linked money laundering—that have touchpoints across the U.S. financial sector.

Illicit fentanyl is primarily synthesized, trafficked, and smuggled into the United States by Mexican cartels. The Sinaloa Cartel and the Cartel Jalisco Nueva Generacion—which are Foreign Terrorist Organizations, Specially Designated Global Terrorists, and Drug Trafficking Organizations—largely control the fentanyl supply chain from Mexico and use precursor chemicals and manufacturing equipment primarily sourced from the People’s Republic of China (PRC) to synthesize illicit fentanyl in clandestine laboratories. FinCEN analysis identified Mexico and the PRC as the top two foreign countries listed in subject address fields of fentanyl-related BSA reports filed in 2024.

FinCEN continues to encourage financial institutions to carefully review its August 2019 and June 2024 advisories on the trafficking of fentanyl, fentanyl analogues, and other synthetic opioids and the precursor chemicals and associated manufacturing equipment needed to synthesize these deadly drugs.

The OCC has issued Bulletin 2025-6 to inform OCC-supervised institutions of the appropriate names and addresses for notices required by the Community Reinvestment Act (CRA) and Equal Credit Opportunity Act, and for posters required by the Fair Housing Act. Banks should make the appropriate changes to their notices and posters, if necessary, within 90 days of this bulletin’s date of issuance [by July 7, 2025]. Yesterday's Bulletin rescinds Bulletin 2021-35.

Community Reinvestment Act - Public Notice by Banks

The CRA public notices must include the physical address of the appropriate Office of the Comptroller of the Currency (OCC) supervisory office and an email address for purposes of informing the public how to (1) obtain a list of banks that are scheduled for CRA examination each quarter, (2) obtain an announcement of bank applications covered by the CRA filed with the OCC, or (3) send written comments about the needs and opportunities in any of the bank’s assessment areas.

The email address for all banks is CRAComments@occ.treas.gov.

Large Bank Supervision
Deputy Comptroller
Large Bank Supervision
Office of the Comptroller of the Currency
400 7th St. SW
Washington, DC 20219

Midsize and Trust Supervision
Deputy Comptroller
Midsize Bank Supervision
Office of the Comptroller of the Currency
400 7th St. SW
Washington, DC 20219

East Region
Deputy Comptroller
East Region
Office of the Comptroller of the Currency
7 Times Square, 10th Floor
New York, NY 10036

Midwest Region
Deputy Comptroller
Midwest Region
Office of the Comptroller of the Currency
1050 17th St., Suite 1500
Denver, CO 80265

Northeast Region
Deputy Comptroller
Northeast Region
Office of the Comptroller of the Currency
7 Times Square, 10th Floor
New York, NY 10036

South Region
Deputy Comptroller
South Region
Office of the Comptroller of the Currency
1700 Pacific Ave., Suite 3600
Dallas, TX 75201

Southeast Region
Deputy Comptroller
Southeast Region
Office of the Comptroller of the Currency
1700 Pacific Ave., Suite 3600
Dallas, TX 75201

West Region
Deputy Comptroller
West Region
Office of the Comptroller of the Currency
1050 17th St., Suite 1500
Denver, CO 80265

Fair Housing Act - Posters

Banks must post and maintain fair housing posters at all of their places of business that participate in the activities subject to the Fair Housing Act. Federal savings associations are required to include in their posters a statement directing persons who believe that they have been discriminated against to send a complaint to the Assistant Secretary for Fair Housing and Equal Opportunity, U.S. Department of Housing and Urban Development, Washington, DC 20410, and to the appropriate federal regulator.

Banks should use the following address in their Fair Housing Act posters:

Office of the Comptroller of the Currency
Customer Assistance Group
P.O. Box 53570
Houston, TX 77052

Banks with $10 billion or less in assets must provide a notice that is substantially similar to the following statement:

The federal Equal Credit Opportunity Act prohibits creditors from discriminating against credit applicants on the basis of race, color, religion, national origin, sex, marital status, or age (provided the applicant has the capacity to enter into a binding contract); because all or part of the applicant’s income derives from any public assistance program; or because the applicant has in good faith exercised any right under the Consumer Protection Act. The federal agency that administers compliance with this law concerning this creditor is:

Office of the Comptroller of the Currency
Customer Assistance Group
P.O. Box 53570
Houston, TX 77052

Banks with more than $10 billion in assets must provide a notice that is substantially similar to the following statement:

The federal Equal Credit Opportunity Act prohibits creditors from discriminating against credit applicants on the basis of race, color, religion, national origin, sex, marital status, or age (provided the applicant has the capacity to enter into a binding contract); because all or part of the applicant’s income derives from any public assistance program; or because the applicant has in good faith exercised any right under the Consumer Protection Act. The federal agency that administers compliance with this law concerning this creditor is:

Consumer Financial Protection Bureau
1700 G St. NW
Washington, DC 20006

The OCC has announced it has notified Congress of a major information security incident, as required by the Federal Information Security Modernization Act. The incident was reported to the public on February 26, 2025.

On February 11, 2025, the OCC learned of unusual interactions between a system administrative account in its office automation environment and OCC user mailboxes. On February 12, the OCC confirmed the activity was unauthorized and immediately activated its incident response protocols, which include initiating an independent third-party incident assessment and reporting the incident to the Cybersecurity and Infrastructure Security Agency. On February 12, the OCC disabled the compromised administrative accounts and confirmed that the unauthorized access had been terminated.

The OCC discovered that the unauthorized access to a number of its executives’ and employees’ emails included highly sensitive information relating to the financial condition of federally regulated financial institutions used in its examinations and supervisory oversight processes.

“The confidentiality and integrity of the OCC’s information security systems are paramount to fulfilling its mission,” said Acting Comptroller of the Currency Rodney E. Hood. “I have taken immediate steps to determine the full extent of the breach and to remedy the long-held organizational and structural deficiencies that contributed to this incident. There will be full accountability for the vulnerabilities identified and any missed internal findings that led to the unauthorized access.”

Yesterday, the U.S. Federal Housing Finance Agency (FHFA) and Fannie Mae issued the following statement:

“In President Trump’s housing market, there is no room for fraud, mortgage fraud, or any other deceitful act that can jeopardize the safety and soundness of the housing industry,” said William J. Pulte, Chairman of the Board of Directors of Fannie Mae. “Since my swearing-in, we fired over 100 employees from Fannie Mae who we caught engaging in unethical conduct, including facilitating fraud, against our great company. Anyone who commits fraud against Fannie Mae does so against the American people.”

The Federal Reserve Board has released its April 7 G.19 report on consumer credit in the month of February 2025.

During February, consumer credit decreased at a seasonally adjusted annual rate of 0.2 percent. Revolving credit increased at an annual rate of 0.1 percent, while nonrevolving credit decreased at an annual rate of 0.3 percent.

The Social Security Administration has published [90 FR 15030] in this morning's Federal Register a Notice of a decrease in the fees across all tiers for the electronic Consent Based Social Security Number (SSN) Verification (eCBSV) service. The revised subscription tier structure will be applicable for subscription payments made on or after April 7, 2025.

The FDIC has released a list of 61 banks whose most recent CRA compliance evaluations were made public in January 2025. Fifty-six of the banks listed received a rating of Satisfactory. Two banks — Community Bank of Raymore, Raymore, Missouri, and Sewickley Savings Bank, Sewickley, Pennsylvania — were rated Needs to Improve.

We congratulate three banks on the list that received Outstanding ratings:

• Bank Hapoalim B.M., New York, New York
• Cambridge Savings Bank, Cambridge, Massachusetts
• Seamen's Savings Bank, Provincetown, Massachusetts

The ABA Banking Journal has reported that the CFPB has said in a court filing that its leadership has directed staff to initiate a new rulemaking to implement section 1071 of the Dodd-Frank Act and plans to release a proposal to potentially replace or change its current rule.

In a court filing in a case brought by the Revenue Bases Finance Coalition in the U.S. District Court for Southern Florida, the CFPB asked the court to suspend any further action until it has proposed a new rule. In the filing, the CFPB said it "anticipates issuing a Notice of Proposed Rulemaking as expeditiously as reasonably possible. Because the anticipated rulemaking process may moot or otherwise resolve this litigation, holding this matter in abeyance would conserve the court’s resources."

The FDIC has published [90 FR 14839] in this morning's Federal Register a notice that it has terminated the receiverships of two institutions, effective April 1, 2025:

• First Bank of Beverly Hills, Calabasas, California
• Liberty Bank, Eugene Oregon

The Treasury Department has reported that OFAC yesterday took action against a network of Houthi financial facilitators and procurement operatives working in coordination with Sa’id al-Jamal, a senior Houthi financial official backed by Iran’s Islamic Revolutionary Guard Corps-Qods Force (IRGC-QF). This network has procured tens of millions of dollars’ worth of commodities from Russia, including weapons and sensitive goods, as well as stolen Ukrainian grain, for onward shipment to Houthi-controlled Yemen. Additionally, OFAC has identified eight digital asset wallets used by the Houthis to transfer funds associated with their activities.

For a link to identification information on the designated individuals and entities, see yesterday’s BankersOnline OFAC Update. The digital wallet information is in the SDN entry listed as changed in OFAC's Notice.

Yesterday, FinCEN reported that Secretary of the Treasury Scott Bessent led a public-private partnership event with 16 systemically important global financial institutions and federal law enforcement agencies, focused on denying Iran access to the global financial system. This event was the first in FinCEN’s “Iran Maximum Pressure and Counter Terrorism” (or IMPACT) Exchange series. The event focused on Iran’s sprawling global oil and “shadow banking” networks.

Yesterday's FinCEN Exchange event enabled the financial sector to better understand challenges in complying with U.S. sanctions on Iran and Iran’s global oil and “shadow banking” sanctions evasion networks. Shadow banking networks are multi-jurisdictional illicit finance systems that grant sanctioned Iranian entities access to the international financial system and obfuscate Iran’s trade with foreign customers. Leaders from financial institutions, law enforcement agencies, and Treasury engaged in robust conversation to share best practices and investigative findings to protect the U.S. financial system from abuse and terrorism.

March 2025 updates [a ZIP file] to the FDIC's Risk Management Manual of Examination Policies (RMS Manual) include changes to Section 3.7 — Other Assets and Liabilities, that (1) align with current Generally Accepted Accounting Practices (GAAP); (2) incorporate references to Part 324 of the FDIC rules and regulations for various topics; and (3) provide examiner guidance on contingent liabilities associated with loan sales and loan servicing activities.

The examiner guidance updates, along with recently added guidance on Government Guaranteed Lending and Government Insured Mortgage Lending (Section 3.2, Loans), have been incorporated in response to recommendations made by the FDIC’s Office of Inspector General in a May 2023 report titled "FDIC Examinations of Government-Guaranteed Loans." Other minor changes were also made to improve the clarity and readability of the RMS Manual.

To assist readers in identifying the changes, the FDIC is providing a redline document that identifies all changes. The FDIC plans to continue this practice when making updates to its exam manuals in the future.

Yesterday, Federal Reserve Board Governor Adriana D. Kugler spoke on "Inflation Expectations and Monetary Policymaking" at the "Public Talk: Reflections on Recent Economic Developments," cosponsored by the Griswold Center for Economic Policy Studies and the Julis-Rabinowitz Center for Public Policy and Finance, Princeton University, Princeton, New Jersey.

The FDIC has issued FIL-8-2025 with information and materials concerning the Consolidated Reports of Condition and Income (Call Report) for the March 31, 2025, report date and provide guidance on certain reporting issues.

There are no new data items that take effect this quarter in the FFIEC 031, FFIEC 041 or FFIEC 051 Call Report forms. Institutions should refer to the attached Supplemental Instructions for March 2025 for additional guidance on certain reporting issues.

To enhance and implement baseline security requirements for federal information systems, the FFIEC is planning to add multifactor authentication (MFA) to the Central Data Repository (CDR) application. CDR staff are working with Call Report software vendors (vendors) to implement the MFA requirements with phased implementation planned for third and fourth quarters of 2025. Vendors may engage in outreach with their bank clients to test end-user implementation of the MFA process prior to that time. CDR staff plans to provide individual notifications to users (both bank and other public users of the CDR) with updated login instructions starting in third quarter 2025.

The Federal Reserve Board has announced it has issued a Consent Order of Prohibition against Nicolas Pérez Alvarado, a former deputy operations manager of a Banco Popular de Puerto Rico, based upon his having pleaded guilty to ten counts of aggravated illegal appropriation and embezzlement under Puerto Rico law for misappropriating $19,800 from the bank (repaid by Pérez Alvarado), and subsequent sentencing to probation.

The Board also announced its termination of a 2022 Cease and Desist Order against Allegiant United Holdings, LLC, Nano Financial Holdings, Inc., and Nano Banc, all of Irvine, California.

Yesterday, the Department of the Treasury reported that OFAC, in coordination with the U.S. Department of Justice, has targeted a network of six entities and two individuals based in Iran, the United Arab Emirates, and the People’s Republic of China responsible for the procurement of unmanned aerial vehicle (UAV) components on behalf of Iran-based Qods Aviation Industries (QAI)—a leading manufacturer for Iran’s UAV program. This network has also facilitated procurement for other entities in Iran's military-industrial complex.

For a link to identification information on the designated individuals and entities, see yesterday's BankersOnline OFAC Update.

The Federal Housing Finance Agency has, in the past several days, rescinded three of its 2024 Advisory Bulletins:

• AB 2024-01 (Climate-Related Risk Management), rescinded March 25, 2025
• AB 2024-04 (Federal Home Loan Bank System Climate-Related Risk Management), rescinded March 27, 2025
• AB 2024-06 (Regulated Entity Unfair or Deceptive Acts or Practices Compliance), rescinded March 24, 2025

Additionally, the FHFA has posted a notice on the front page of its site that it is "in the process of rescinding or revising guidance and policies posted on this webpage in accordance with Executive Order 14151 Ending Radical and Wasteful Government DEI Programs and Preferencing, and Executive Order 14168 Defending Women from Gender Ideology Extremism and Restoring Biological Truth to the Federal Government. In the interim, any previously issued diversity, equity, inclusion or gender-related guidance on this website should be considered rescinded."

The OCC has released a list of 18 Community Reinvestment Act (CRA) performance evaluations that became public in March. Ten of those evaluations received ratings of Satisfactory.

We congratulate the remaining eight of the institutions for having evaluations that received ratings of Outstanding:

• Barrington Bank & Trust Company, National Association, Barrington, IL
• Beverly Bank & Trust Company, National Association, Chicago, IL
• Central Savings, F.S.B., Chicago, IL
• First Dakota National Bank, Yankton, SD
• First Pioneer National Bank, Wray, CO
• Fulton Bank, National Association, Lancaster, PA
• Patrons Bank, National Association, Okmulgee, OK
• The Santa Anna National Bank, Santa Anna, TX

Yesterday, FinCEN announced it has issued Advisory FIN-2025-A001 to help financial institutions identify and report suspicious activity related to the financing of the Islamic State of Iraq and Syria (ISIS).

The Advisory highlights how ISIS and its global affiliates fund themselves and receive financial support from sympathizers internationally and describes several typologies ISIS uses to transfer money between its affiliates. The Advisory also provides red flags that may assist financial institutions in identifying related suspicious activity.

FinCEN has announced it has issued FIN-2025-Alert001, FinCEN Alert on Bulk Cash Smuggling and Repatriation by Mexico-Based Transnational Criminal Organizations, urging financial institutions to be vigilant in identifying and reporting transactions potentially related to the cross-border smuggling of bulk cash from the United States into Mexico and the repatriation of bulk cash into the U.S. and Mexican financial systems by Mexico-based transnational criminal organizations (TCOs).

The Alert highlights one of several typologies that TCOs use to launder illicit proceeds generated in the United States through the cross-border movement of cash and how these operations enable the TCOs to place, layer, and integrate their illicit proceeds into the United States and Mexican financial systems where they can be accessed again to fund their criminal enterprises. It provides an overview of methodologies associated with these operations, highlights red flag indicators, and reminds financial institutions of their reporting requirements under the Bank Secrecy Act.

The Federal Trade Commission reports it has sent letters to operators of websites that sell Employer Identification Number (EIN) filing and delivery services warning that some of their practices may violate the FTC Act and the Impersonation Rule, which prohibit posing as or misrepresenting affiliation with a government agency. According to the letters, these services charge consumers up to $300 per EIN even though consumers can obtain EINs for free directly from the Internal Revenue Service’s website.

The OCC has announced its offering of six community bank director and senior management workshops.

The CFPB has stated it plans to revoke its "Use of Digital User Accounts to Access Buy Now, Pay Later Loans" interpretive rule [89 FR 47068, May 31, 2024] in a Status Report and Joint Motion to Stay in Financial Technology Association v. Consumer Financial Protect Bureau in the U.S. District Court for the District of Columbia.

The NCUA has announced it issued four consent orders and two prohibition notices in March 2025 to individuals who are now prohibited from participating in the affairs of any federally insured depository institution. The orders and notices were issued against:

• Lindsay Risinger, a former employee of Barton Plan Employees Federal Credit Union in Luling, Louisiana
• Stephen Hopkins, a former employee of HealthPlus Federal Credit Union in Jackson, Mississippi
• Edward Nurse, a former employee of Park Side Financial Credit Union in Whitefish, Montana
• Nadaje Hendrix, a former employee of Hanscom Federal Credit Union in Middlesex, Massachusetts
• Jovan Eric Bell, a former employee of Navy Federal Credit Union in Vienna, Virginia
• Jalen Craig McMillan, a former employee of Navy Federal Credit Union in Vienna, Virginia

The CFPB has announced that the Home Mortgage Disclosure Act (HMDA) Modified Loan Application Register (LAR) data for 2024 are now available on the Federal Financial Institutions Examination Council's (FFIEC) HMDA Platform for approximately 4,898 HMDA filers.

The published data contain loan-level information filed by financial institutions and modified to protect consumer privacy. A downloadable modified LAR file is available for every financial institution that has completed a HMDA data submission in the selected year. The modified LAR data represents the most current HMDA submission made by an institution.

Typically, some data resubmissions to correct errors occur during the weeks following the annual submission deadline. For this reason, data users may want to wait for the release of the Snapshot National Loan-Level Dataset to analyze the nationwide data.

The Department of the Treasury has announced that OFAC has designated six individuals and seven entities involved in a money laundering network supporting the Sinaloa Cartel. The Sinaloa Cartel is responsible for a significant portion of the illicit fentanyl and other deadly drugs trafficked into the United States and has exploited multiple ports of entry along the southern border for its criminal activities.

Treasury also reported that FinCEN had issued an alert urging financial institutions to be vigilant to bulk cash smuggling and repatriation by Mexico-based transnational criminal organizations. The alert outlines methodologies associated with these operations and highlights red flag indicators in an effort to better equip financial institutions to counter this illicit activity.

• Chart of the Sinaloa Cartel Money Laundering Network

The Department of State announced its designation of six individuals who have engaged in actions or policies that threaten to further erode the autonomy of Hong Kong in contravention of China’s commitments, and in connection with acts of transnational repression.

For a link to names and identification information on the OFAC and State Department designated parties, see the March 31, 2025, BankersOnline OFAC Update.

The Department of Housing and Urban Development Office of Housing, Multifamily Housing, and Office of Public and Indian Housing have published [90 FR 14376] in this morning's Federal Register a notice of a new matching program between the U.S. Department of Housing and Urban Development (HUD) and the Department of the Treasury, Bureau of the Fiscal Service, Do Not Pay (DNP) Treasury Working System.

This program aims to enhance the detection and prevention of fraud, waste, abuse and improper and unsupported payments in Federal benefit programs administered by HUD. Comments on the notice must be received no later than May 1, 2025. If no public comments are received by that time, the new agreement will become effective on May 1, 2025.

The OCC yesterday reported it has withdrawn its participation in the interagency principles for climate-related financial risk management for large financial institutions.

"The principles providing guidance to banks for climate-related financial risk are overly burdensome and duplicative. The OCC’s existing guidance for banks to maintain a sound risk management framework applies to all activities conducted by supervised institutions and includes potential exposures to severe weather events or natural disasters,” said Acting Comptroller of the Currency Rodney E. Hood."