March 31, 2025

SEC Adopts Reforms Relating to Investment Advisers Operating Exclusively Through the Internet

The Securities and Exchange Commission today adopted amendments to the rule permitting certain internet investment advisers to register with the Commission (the “internet adviser exemption”). The amendments will require an investment adviser relying on the internet adviser exemption to have at all times an operational interactive website through which the adviser provides digital investment advisory services on an ongoing basis to more than one client. The amendments will also eliminate the current rule’s de minimis exception by requiring an internet investment adviser to provide advice to all of its clients exclusively through an operational interactive website and to make certain corresponding changes to Form ADV.

Action Item: Investment advisors who fall under the definition of an “internet investment advisor” must comply with the rule’s requirements by March 31, 2025.

January 1, 2025

FCA approves final rule on cyber risk management to enhance Farm Credit System security and spur innovation

The Farm Credit Administration board has approved a final rule on cyber risk management. The rule requires each System institution to develop and implement a comprehensive, written cyber risk management program.

Action Item: Farm credit institutions should review the final rule, and update policies to comply with the changes by the effective date. Institutions should also provide applicable training closer to the effective date.

November 16, 2024

SEC Adopts Rules to Improve Clearing Agency Governance and Mitigate Conflicts of Interest

The Securities and Exchange Commission has adopted new rules to improve the governance of all registered clearing agencies by reducing the likelihood that conflicts of interest may influence their boards of directors or equivalent governing bodies. The new rules establish governance requirements regarding board composition, independent directors, nominating committees, and risk management committees. The rules also require new policies and procedures regarding conflicts of interest, management of risks from relationships with service providers for core services, and a board obligation to consider stakeholder viewpoints. The rules are being adopted pursuant to, among other statutory provisions, Section 765 of the Dodd-Frank Act, which specifically directs the Commission to adopt rules to mitigate conflicts of interest for security-based swap clearing agencies. The rules improve the governance of registered clearing agencies by identifying certain responsibilities of the board, increasing transparency into board governance, and, more generally, improving the alignment of incentives among owners and participants of a registered clearing agency. In support of these objectives, the rules establish new requirements for board and committee composition, independent directors, management of conflicts of interest, and board oversight.

Action Item: All registered clearing agencies must develop policies and procedures to comply with the rules. The policies also need to address the new governance requirements regarding board composition, independent directors, nominating committees, and risk management committees.

September 1, 2024

SEC Adopts Rules for the Registration and Regulation of Security-Based Swap Execution Facilities

The Securities and Exchange Commission today adopted new Regulation SE under the Securities Exchange Act of 1934 to create a regime for the registration and regulation of security-based swap execution facilities (SBSEFs). The new regulatory framework was required under Title VII of the Dodd-Frank Wall Street Reform and Consumer Protection Act relating to the over-the-counter derivatives market. The adoption addresses the Exchange Act’s trade execution requirement for security-based swaps and the cross-border application of that requirement, implements Section 765 of the Dodd-Frank Act to mitigate conflicts of interest at SBSEFs and national securities exchanges that trade security-based swaps, and promotes consistency between Regulation SE and existing rules under the Exchange Act. In adopting Regulation SE, the Commission has sought to harmonize as closely as practicable with parallel rules of the CFTC that govern swap execution facilities (SEFs) and swap execution generally. The adopted rules will become effective 60 days following the date of publication in the Federal Register. Any entity that meets the definition of SBSEF may file an application to register with the Commission on Form SBSEF at any time after the effective date, and would need to do so within 180 days of the effective date and have its application on Form SBSEF be complete within 240 days of the effective date in order to continue to operate as an SBSEF while its application is pending.

Action Item: Any entity that meets the definition of SBSEF may file an application to register with the Commission on Form SBSEF at any time after the effective date, and would need to do so within 180 days of the effective date and have its application on Form SBSEF be complete within 240 days of the effective date in order to continue to operate as an SBSEF while its application is pending.

September 30, 2024

SEC Adopts Amendments to Rules Governing Beneficial Ownership Reporting

The Securities and Exchange Commission adopted rule amendments governing beneficial ownership reporting under Sections 13(d) and 13(g) of the Securities Exchange Act of 1934. The amendments update Regulation 13D-G to require market participants to provide more timely information on their positions to meet the needs of investors in today’s financial markets.

Action Item: Publicly traded companies should familiarize themselves with the amendments, including the content and timing disclosure requirements.

June 1, 2024

FinCEN Seeks Comments on Customer Identification Program Requirement

The U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) is issuing a request for information (RFI) related to existing requirements for banks under the Customer Identification Program (CIP) Rule to collect a taxpayer identification number (TIN) from a customer prior to opening an account. Generally, for a customer who is an individual and a U.S. person, banks are required to collect a full Social Security number (SSN) from a customer. The RFI is being issued in consultation with staff at the Office of the Comptroller of the Currency, the Federal Deposit Insurance Corporation, the National Credit Union Administration, and the Board of Governors of the Federal Reserve System.

Action Item: Financial institutions should submit comment to FinCEN.

Course Updates: (Release Date TBD)

4000B / 4000C / 4000M / 4000N – CIP: CDD and Beneficial Ownership
30323B / 30323C / 30323M / 30323N – CIP Procedures and Protections
30501B / 30501C / 30501M / 30501N – BSA and AML: Comprehensive
30502B / 30502C / 30502M / 30502N – BSA and AML: Essentials
31104B / 31104C / 31104N – Frontline: CIP and FCRA for Opening Deposit Accounts
31136B / 31136C / 31136N – Frontline: BSA and AML

June 9, 2024

Federal Reserve Board announces final rule that updates risk management requirements for certain systemically important financial market utilities (FMUs) supervised by the Board

The final updates provide additional clarity and specificity to existing requirements in four key areas of operational risk management: incident management and notification; business continuity management and planning; third-party risk management; and review and testing of operational risk management measures. For example, the updates explicitly require FMUs to establish an incident management framework and emphasize the need for FMUs to continue to advance their cyber resilience capabilities.

Action Item: Systematically important financial market utilities should incorporate the final rule’s requirements into institutional risk management policies and procedures.

June 30,  2024

Federal judge delays Section 1071 compliance dates; temporary relief applies only to ABA, TBA members

A federal judge in Texas issued an order blocking enforcement of the Consumer Financial Protection Bureau’s Section 1071 final rule while the Supreme Court hears a challenge to the constitutionality of the CFPB’s funding structure. While the judge granted ABA and TBA’s request for an injunction, the judge did not accept ABA’s and TBA’s request for the injunction to apply to all lenders covered by the rule but chose to provide relief only to TBA and ABA member banks across the country. The relief applies while the Supreme Court hears the constitutional challenge to the CFPB in CFPB v. Community Financial Services Association of America, which is scheduled to be argued in October and whose decision could be released any time before the end of June 2024, at which point new compliance deadlines would be issued for ABA and TBA members. “Defendants are ordered to extend Plaintiffs and their members’ deadlines for compliance with the requirements of the Final Rule to compensate for the period stayed,” the judge’s order said. The ruling would thus allow ABA and TBA members to limit Section 1071 implementation costs until the question of the CFPB’s constitutionality is resolved.

Course Updates: (Release Date TBD)

30260B / 30260C / 30260N – The Small Business Lending Rule

Action Item: Members of the ABA and TBA should continue to understand the requirements under Section 1071, but pay be aware of the Supreme Court’s decision on the lawsuit, which is expected to be release in the middle of 2024.

All other applicable financial institutions should continue to implement the requirements and plan on fully complying by the applicable effective date.

May 5, 2024

CFPB Bans Excessive Credit Card Late Fees, Lowers Typical Fee from $32 to $8

The Consumer Financial Protection Bureau (CFPB) finalized a rule today to cut excessive credit card late fees by closing a loophole exploited by large card issuers. It lowers the amount an issuer can charge for late fees to $8, however exceptions are permissible for large  issuers in situations where they can prove the higher fee is necessary to cover their actual collection costs. It also ends the abuse of the automatic annual inflation adjustment. The CFPB’s final rule applies to the largest credit card issuers, those with more than 1 million open accounts.

Action Item: Credit card issuers with more than 1 million open accounts should update policies, procedures, processes, and disclosures to comply with the final rule.

May 10, 2024

SEC Adopts Amendments to Enhance Disclosure of Order Execution Information

The Securities and Exchange Commission today adopted rule amendments that update the disclosure required under Rule 605 of Regulation NMS for order executions in national market system stocks (NMS stocks), which are stocks listed on a national securities exchange. Rule 605 was adopted in 2000 to help the public compare and evaluate execution quality at different market centers.

Action Item: Publicly traded companies should review the rule and update execution quality report policies accordingly.

SEC Adopts Rules to Enhance and Standardize Climate-Related Disclosures for Investors

The Securities and Exchange Commission today adopted rules to enhance and standardize climate-related disclosures by public companies and in public offerings. The final rules reflect the Commission’s efforts to respond to investors’ demand for more consistent, comparable, and reliable information about the financial effects of climate-related risks on a registrant’s operations and how it manages those risks while balancing concerns about mitigating the associated costs of the rules.

Action Item: Publicly traded companies should update investor disclosure policies accordingly.

May 12, 2024

Federal Reserve Extends the Comment Period on Interchange Fee Proposal

Interchange fees are paid by merchants and received by debit card issuers for each debit card transaction. In October 2023, the Board requested comment on a proposal to lower the maximum interchange fee that a large debit card issuer can receive for a debit card transaction. The proposal would also establish a regular process for updating the maximum amount every other year going forward. By law, the Board is required to establish standards for assessing whether an interchange fee received by a large debit card issuer for processing a debit card transaction is reasonable and proportional to certain issuer costs.

Action Item: Debit card issuers should submit comment on the proposed rule.

Course Updates: (Release Date TBD)

30212B / 30212C / 30212N – Reg II: How Interchange Fees Affect Your Institution

Federal Bank Regulatory Agencies Seek Comment on Interagency Effort to Reduce Regulatory Burden

The federal bank regulatory agencies today published their first of a series of requests for comment to reduce regulatory burden. The Economic Growth and Regulatory Paperwork Reduction Act of 1996 requires the Federal Financial Institutions Examination Council and federal bank regulatory agencies to review their regulations every 10 years to identify any outdated or otherwise unnecessary regulatory requirements for their supervised institutions.

Action Item: Financial institutions should submit comment to their federal regulators.

May 24, 2024

FDIC Seeks Public Comment on Proposed Revisions to its Statement of Policy on Bank Merger Transactions

The revised SOP reflects legislative and other developments that have occurred since it was last amended in 2008, including the establishment of the statutory factor regarding the risk to the stability of the United States banking or financial system.  The revised SOP is principles based; describes the types of applications subject to FDIC approval; addresses each statutory factor separately; and highlights other relevant matters and considerations, such as related statutes pertaining to interstate mergers, and applications from non-banks or banks that are not traditional community banks.  Further, the revised SOP reflects consideration of comment letters received in response to the FDIC’s March 2022 Request for Information and Comment on Rules, Regulations, Guidance, and Statements of Policy Regarding Bank Merger Transactions.

Action Item: Banks regulated by the FDIC should submit comment on the proposed SOP.

April 1, 2024

CFPB Proposes Rule to Close Bank Overdraft Loophole that Costs Americans Billions Each Year in Junk Fees

The Consumer Financial Protection Bureau (CFPB) today proposed a rule  to rein in excessive overdraft fees charged by the nation’s biggest financial institutions. The proposal would close an outdated loophole that exempts overdraft lending services from longstanding provisions of the Truth in Lending Act and other consumer financial protection laws.Essentially, the proposal would cap fees for banks and credit unions with more than $10 billion in assets. Banks with assets of less than $10 billion would be exempt. Under the proposal, large banks would be free to extend overdraft loans if they complied with longstanding lending laws, including disclosing any applicable interest rate. Alternatively, banks could charge a fee to recoup their costs at an established benchmark – as low as $3, or at a cost they calculate, if they show their cost data. The CFPB has proposed benchmarks of $3, $6, $7, or $14 and is seeking comment on the appropriate amount.

Action Item: Depository institutions should submit comment on the proposed rule.

Course Updates: (Release Date TBD)

BAI will release new and updated courses upon finalization of the rule.

April 1, 2024

FDIC Approves Final Rule Regarding Deposit Insurance Simplification

The final rule simplifies deposit insurance coverage for deposits held in connection with revocable and irrevocable trusts by merging these two deposit insurance categories and applying a simpler, common calculation to determine coverage. Currently, the FDIC receives more inquiries related to deposit insurance coverage for trust deposits than all other types of deposits combined. The final rule will make the trust rules consistent and easier to understand for bankers and depositors and will facilitate prompt payment of deposit insurance by the FDIC in the event of an insured depository institution’s failure. Meanwhile, the FDIC expects that the vast majority of trust depositors will experience no change in the coverage for their deposits when the final rule takes effect.

Course Updates: (Release Date February 2, 2024)

30328B  – Federally Insured Accounts

April 6, 2024

SEC Adopts Rules to Include Certain Significant Market Participants as “Dealers” or “Government Securities Dealers”

The Rules Are Intended to Require Additional Market Participants, Including Certain Proprietary Trading Firms, Private Funds and Investment Advisers, to Register with the SEC as Dealers or Government Securities Dealers. The Final Rules and related adopting release also provided additional guidance regarding some of the key terms and concepts, including the “own account” definition. Under the final rules, any person that engages in activities as described in the rules is a “dealer” or “government securities dealer” and, absent an exception or exemption, required to: register with the Commission under Section 15(a) or Section 15C, as applicable; become a member of an SRO; and comply with federal securities laws and regulatory obligations and applicable SRO and Treasury rules and requirements.

Action Item: Organizations that participate in the activities described in the final rule must be properly registered and comply with the requirements of the SEC in connection with certain liquidity-providing roles.

April 11, 2024

FTC Implements New Protections for Businesses Against Telemarketing Fraud and Affirms Protections Against AI-enabled Scam Calls

The Federal Trade Commission today announced a final rule extending telemarketing fraud protections to businesses and updating the rule’s recordkeeping requirements in light of developments in technology and the marketplace. The Commission also announced a proposed rule that would provide the agency with significant new tools to combat tech support scams.

Action Item: Institutions should review current telemarketing and robocall policies and verify they are in compliance with the rule.

April 13, 2024

FinCEN Proposes Rule to Combat Money Laundering and Promote Transparency in Residential Real Estate

The proposed rule would require certain professionals involved in real estate closings and settlements to report information to FinCEN about non-financed transfers of residential real estate to legal entities or trusts. FinCEN’s proposal is tailored to target residential real estate transfers considered to be high-risk for money laundering, while minimizing potential business burden, and it would not require reporting of transfers made to individuals.

Action Item: Real estate professionals should submit comment on the proposed rule.

Course Updates: (Release Date TBD)

BAI will release new and updated courses upon finalization of the rule.

April 14, 2024

FinCEN Proposes Rule to Combat Illicit Finance and National Security Threats in Investment Adviser Sector

Today, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued a Notice of Proposed Rulemaking (NPRM) to keep criminals and foreign adversaries from exploiting the U.S. financial system and assets through investment advisers. This proposed rule, which complements Treasury’s other recent actions to combat the illicit finance risks from anonymous companies and all-cash real estate transactions, will add further transparency to the U.S. financial system and help assist law enforcement in identifying illicit proceeds entering the U.S. economy.

Action Item: Financial advisors should submit comment on the proposed rule.

Course Updates: (Release Date TBD)

BAI will release new and updated courses upon finalization of the rule.

April 20, 2024

FTC Proposes New Protections to Combat AI Impersonation of Individuals

The Federal Trade Commission is seeking public comment on a supplemental notice of proposed rulemaking that would prohibit the impersonation of individuals. The proposed rule changes would extend protections of the new rule on government and business impersonation that is being finalized by the Commission today.

Action Item: Financial institutions should submit comment on the proposed rule.

April 27, 2024

FTC Amends Safeguards Rule to Require Non-Banking Financial Institutions to Report Data Security Breaches

The Federal Trade Commission has approved an amendment to the Safeguards Rule that would require non-banking institutions to report certain data breaches and other security events to the agency. The FTC’s Safeguards Rule requires non-banking financial institutions, such as mortgage brokers, motor vehicle dealers, and payday lenders, to develop, implement, and maintain a comprehensive security program to keep their customers’ information safe. The amendment requires financial institutions to notify the FTC as soon as possible, and no later than 30 days after discovery, of a security breach involving the information of at least 500 consumers. Such an event requires notification if unencrypted customer information has been acquired without the authorization of the individual to which the information pertains. The notice to the FTC must include certain information about the event, such as the number of consumers affected or potentially affected.

Action Item: Nonbank financial institutions should review the amendment, and update policies, procedures, and training to comply with the new requirements for communication of data breaches of a certain size.

Course Updates: (Release Date March 26, 2024)

4105N – Cybersecurity Incident Notification Requirements
30190B / 30190C / 30190M / 30190N – Understanding and Implementing FTC Safeguards Rule Compliance

March 21, 2024

FCC Adopts Rules to Empower Consumers to Stop Robocalls & Robotexts

Here we take steps both to establish new consent protections and to make explicit those protections the Commission failed to codify in the past.  More specifically, we strengthen consumers’ ability to revoke consent so that it is simple and easy, codify previously adopted protections that make it simpler for consumers to revoke consent, and require that callers and texters implement requests in a timely manner.   We also seek comment on whether the TCPA applies to robocalls and robotexts from wireless providers to their own subscribers and seek comment on the ability to revoke consent and thereby stop these communications.

Action Item: Institutions should submit comment on the proposed rule.

March 25, 2024

CFPB Proposes Rule to Stop New Junk Fees on Bank Accounts

The Consumer Financial Protection Bureau (CFPB) proposed today to block banks and other financial institutions from one potential source of new junk fee revenue – fees on transactions declined right at the swipe, tap, or click. The proposed rule would prohibit non-sufficient funds (NSF) fees on transactions that financial institutions decline in real time. These types of transactions include declined debit card purchases and ATM withdrawals, as well as some declined peer-to-peer payments. The CFPB’s proposal is part of the agency’s proactive approach to protect consumers, and it would cover banks, credit unions, and certain peer-to-peer payment companies.

Action Item: Depository institutions should submit comment on the proposed rule.

Course Updates: (Release Date TBD)

BAI will release new and updated courses upon finalization of the rule.

March 26, 2024

TCPA One-to-One Consent Rule Effective January 2025

The Federal Communications Commission (FCC) adopted rules intended to close the so-called “lead generator loophole” in the Telephone Consumer Protection Act (TCPA). According to the FCC, “lead-generated communications are a large percentage of unwanted calls and texts” received by consumers. To close this “loophole,” the FCC amended the definition of “prior express written consent” to “make it unequivocally clear” that lead generators and comparison-shopping websites (that generate a lead for a “seller”) must obtain a consumer’s consent to receive “robocalls” and “robotexts” (i.e., sent utilizing an autodialer, or artificial or prerecorded voice) “one seller at a time,” rather than having a single blanket consent applicable to multiple sellers at once. The rules were published in the Federal Register on January 26, 2024, with a delayed effective date of January 27, 2025, for the “one-to-one consent requirement.” The one-to-one consent must be in response to a “clear and conspicuous” disclosure to the consumer, and the content of the robocalls/texts must be “logically and topically associated with” the website where the consumer gave consent. In this rulemaking, the FCC also codified the agency’s long-held position that the National Do-Not-Call (DNC) Registry protections apply to text messages as “calls” under the TCPA. The DNC regulations now explicitly restrict telemarketing calls and text messages to wireless numbers when the consumer has added the number to the National DNC Registry. Implemented certain changes for wireless service providers, requiring them to block text messages from specific numbers when notified by the FCC of illegal texts from those numbers. “Encouraged” wireless providers to make email-to-text an opt-in service to reduce the number of fraudulent text messages consumers receive that originate from email addresses rather than telephone numbers. The FCC has proposed to make this a requirement in the future.

Action Item: Organizations that engage in activity that meets the definition of “robocalls” and “robotexts” should update their policies, procedures, and processes to comply with the new consent rules issued by the FCC.

February 13, 2024

FTC to Hold Informal Hearing on Proposed Rule Banning Fake Reviews and Testimonials

The Federal Trade Commission will hold an informal hearing on its proposed rule banning fake reviews and testimonials at 10 a.m. ET on February 13, 2024. During the hearing, which will be open to the public and available via webcast, three interested parties will provide oral statements addressing issues raised during the rulemaking process.

Action Item: Institutions should attend the hearing if interested.

January 1, 2024

FinCEN Issues Initial Beneficial Ownership Information Reporting Guidance

The Financial Crimes Enforcement Network (FinCEN) published its first set of guidance materials to aid the public, and in particular the small business community, in understanding upcoming beneficial ownership information (BOI) reporting requirements taking effect on January 1, 2024. The new regulations require many corporations, limited liability companies, and other entities created in or registered to do business in the United States to report information about their beneficial owners the persons who ultimately own or control the company to FinCEN. The guidance also includes FAQ’s, key questions, key filing questions, and multiple introductory videos.

Action Item: Business that will need to start reporting beneficial ownership information should review the guidance and verify that their policies adhere to it.

January 1, 2024

Truth in Lending (Regulation Z) Annual Threshold Adjustments (Credit Cards, HOEPA, and Qualified Mortgages)

The Bureau is required to calculate annually dollar amounts for several provisions in Regulation Z; this final rule revises, as applicable, dollar amounts for provisions implementing TILA and amendments to TILA that impact HOEPA Loans and Qualified Mortgages. The Bureau is adjusting these amounts, where appropriate, based on the annual percentage change reflected in the Consumer Price Index (CPI) in effect on June 1, 2023.

Action Item: All institutions should update Policies and Procedures with the appliable inflationary adjustments and implement them on January 1, 2024, when the rule becomes effective.

Course Updates: (Release Date October 3, 2023)

30420B / 30420C / 30420M / 30420N – Reg Z: Fundamentals for Real Estate Loans

Agencies Announce Dollar Thresholds for Smaller Loan Exemption from Appraisal Requirements for Higher-priced Mortgage Loans

The Consumer Financial Protection Bureau, the Federal Reserve Board, and the Office of the Comptroller of the Currency today announced that the 2024 threshold for whether higher-priced mortgage loans are subject to special appraisal requirements will increase from $31,000 to $32,400. The threshold amount will be effective January 1, 2024, and is based on the annual percentage increase in the Consumer Price Index for Urban Wage Earners and Clerical Workers, known as CPI-W, as of June 1, 2023.

Action Item: All institutions should update policies and procedures with the threshold adjustments, if necessary.

FinCEN Issues Small Entity Compliance Guide for Corporate Transparency Act

The Financial Crimes Enforcement Network (“FinCEN”) has published a Small Entity Compliance Guide (the “Guide”) for beneficial ownership information (“BOI”) reporting under the Corporate Transparency Act (“CTA”), as well as updated FAQs regarding CTA compliance.

Action Item: Institutions should review the guide and the FAQs to understand the requirements, and assist small entities with questions or confusion related to the new rule.

Federal Reserve Board finalizes a rule establishing capital requirements for insurers supervised by the Board

The Federal Reserve Board on Friday finalized a rule establishing capital requirements for insurers supervised by the Board. The final rule is substantially similar to the proposal issued in September 2019. The final rule includes a framework, known as the Building Block Approach, that builds on existing state-based insurance requirements, accounts for risks that are specific to the business of insurance, and is different from the calculations used for bank capital requirements. Under the Building Block Approach, a Board-supervised insurer is required to aggregate its top-tier company’s capital requirements with its subsidiaries’ requirements to determine its enterprise-wide requirement.

Action Item: State-based insurance organizations supervised by the Federal Reserve should review the final rule and update policies, procedures, processes to comply with the requirements.

CFPB announces asset-size threshold adjustments

In September of this year, the CFPB announced several annual threshold adjustment final rules. The CFPB recently released additional thresholds for Regulation M and FCRA. For Regulation M, based on the annual percentage increase in the CPI-W as of June 1, 2023, the exemption threshold will increase from $66,400 to $69,500, effective Jan. 1, 2024. For FCRA, the Bureau of Consumer Financial Protection (Bureau) announces that the ceiling on allowable charges under section 612(f) of the Fair Credit Reporting Act (FCRA) will increase to $15.50, effective for 2024.

Action Item: All institutions should update policies and procedures with the threshold adjustments, if necessary.

Course Updates: (Release Date November 11, 2023)

30420B / 30420C / 30420M / 30420N – Reg Z: Fundamentals for Real Estate Loans

Final Rule on Special Assessment Pursuant to Systemic Risk Determination

The Federal Deposit Insurance Corporation (FDIC) Board of Directors approved a final rule to implement a special assessment to recover the loss to the Deposit Insurance Fund (DIF) associated with protecting uninsured depositors following the closures of Silicon Valley Bank and Signature Bank. The Federal Deposit Insurance Act (FDI Act) requires the FDIC to take this action in connection with the systemic risk determination announced on March 12, 2023. Under the final rule, the banks that benefited most from the assistance provided under the systemic risk determination will be charged a special assessment to recover losses to the DIF resulting from the protection of uninsured depositors. In general, large banks and regional banks, and particularly those with large amounts of uninsured deposits, were the banks most vulnerable to uninsured deposit runs and benefited most from the stability provided under the systemic risk determination. The FDIC estimates that 114 banking organizations will be subject to the special assessment, including 48 banking organizations with total assets over $50 billion and 66 banking organizations with total assets between $5 and $50 billion. No banking organizations with total assets under $5 billion will pay a special assessment, based on data for the December 31, 2022 reporting period. The special assessment will be collected at an annual rate of approximately 13.4 basis points for an anticipated total of eight quarterly assessment periods. Because the estimated loss pursuant to the systemic risk determination will be periodically adjusted, the FDIC retains the ability to cease collection early, impose an extended special assessment collection period after the initial eight-quarter collection period to collect the difference between losses and the amounts collected, and impose a one-time final shortfall special assessment after both receiverships terminate. The special assessment will be collected beginning with the first quarterly assessment period of 2024 (i.e., January 1 through March 31, 2024) with an invoice payment date of June 28, 2024.

Action Item: Banks with total assets of $5 Billion or more should begin to prepare to start paying the assessments for the depleted Federal Deposit Insurance Fund.

January 2, 2024

Federal Reserve announces pricing for payment services the Federal Reserve Banks provide to banks and credit unions

By law, the Federal Reserve must establish fees to recover the costs, including imputed costs, of providing payment services over the long run. The Federal Reserve expects to recover 103 percent of actual and imputed expenses in 2024, including the return on equity that would have been earned if a private-sector firm provided the services. Overall, the Reserve Banks estimate that the price changes for 2024 will result in a 1.8 percent average price increase for established, mature services.

Action Item: Banks and credit unions should update policies and procedures for transactions involving Federal Reserve Banks.

January 13, 2024

SEC Adopts Rule to Increase Transparency Into Short Selling and Amendment to CAT NMS Plan for Purposes of Short Sale Data Collection

The Securities and Exchange Commission adopted new Rule 13f-2 to provide greater transparency to investors and other market participants by increasing the public availability of short sale related data. Congress directed the SEC in Section 929X of the Dodd-Frank Act of 2010 to promulgate rules to make certain short sale data publicly available. Specifically, Rule 13f-2 will require institutional investment managers that meet or exceed certain thresholds to report on Form SHO specified short position data and short activity data for equity securities.

Action Item: Publicly traded companies should develop an understanding about the content, and timing requirements related to institutional investment managers that meet or exceed certain thresholds to report on Form SHO specified short position data and short activity data for equity securities.

January 16, 2024

Agencies Request Comment on Proposed Rules to Strengthen Capital Requirements for Large Banks

Bank regulatory agencies today requested comment on a proposal to increase the strength and resilience of the banking system. The proposal would modify large bank capital requirements to better reflect underlying risks and increase the consistency of how banks measure their risks.

Action Item: Federally regulated banks and credit unions should submit comment on the proposed capital requirements.

Agencies Extend Comment Period on Proposed Rule to Require Large Banks to Maintain Long-term Debt

Federal bank regulatory agencies announced today that they will extend until January 16, 2024, the comment period on their long-term debt proposed rule to improve the resolvability of large banks and enhance financial stability. The agencies extended the comment period to allow interested parties more time to analyze the issues and prepare their comments.

Action Item: Banks should submit comment on the proposed rule.

January 21, 2024

FinCEN Proposes New Regulation to Enhance Transparency in Convertible Virtual Currency Mixing and Combat Terrorist Financing

Today, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) announced a Notice of Proposed Rule Making (NPRM) that identifies international Convertible Virtual Currency Mixing (CVC mixing) as a class of transactions of primary money laundering concern. This NPRM highlights the risks posed by the extensive use of CVC mixing services by a variety of illicit actors throughout the world and proposes a rule to increase transparency around CVC mixing to combat its use by malicious actors including Hamas, Palestinian Islamic Jihad, and the Democratic People’s Republic of Korea (DPRK). The NPRM is a key part of Treasury’s efforts to promote transparency for CVC mixing activities.

Action Item: Financial institutions should submit comment on the proposed rule.

Basel publishes crypto exposure proposal

According to the draft guidance, banks would be required to disclose qualitative information on their activities related to cryptoassets and quantitative information on exposures to cryptoassets and the related capital and liquidity requirements.

Action Item: Banks with assets subject to Basel capital requirements should review the proposal and submit comment as applicable.

January 25, 2024

Federal Reserve requests comment on proposal to lower the maximum interchange fee large debit card issuers can receive for debit card transactions

The Federal Reserve Board on Wednesday requested comment on a proposal to lower the maximum interchange fee that a large debit card issuer can receive for a debit card transaction. The proposal would also establish a regular process for updating the maximum amount every other year going forward. By law, the Board is required to establish standards for assessing whether an interchange fee received by a large debit card issuer for processing a transaction is reasonable and proportional to certain issuer costs.

Action Item: Debit card issuers with consolidated assets of $10 billion or more should review the proposed rule and provide comments as applicable prior to the comment period due date.

December 1, 2023

Listing Standards for Recovery of Erroneously Awarded Compensation

The final rules direct the national securities exchanges and associations that list securities to establish listing standards that require each issuer to develop and implement a policy providing for the recovery, in the event of a required accounting restatement, of incentive-based compensation received by current or former executive officers where that compensation is based on the erroneously reported financial information.  In addition, the listing standards must require the disclosure of the policy.  Additionally, the final rules require a listed issuer to file the policy as an exhibit to its annual report and to include other disclosures in the event a recovery analysis is triggered under the policy. The effective date of the rules is October 2, 2023, and NYSE- and Nasdaq-listed issuers are required to adopt compliant clawback policies no later than December 1, 2023.

Action Item: NYSE and NASDAQ-listed issuers should update policies and procedures to address the noted changes, and train applicable staff so they both understand and will comply with the new rules.

December 8, 2023

Business Continuity Management Policy and Policy Consideration Update

The Business Continuity Management Policy Template and related Policy Consideration have been updated. They will be available to Policy Manager clients by Friday, December 8th. Changes were made to include declaration of emergency plans, a revised liquidity section, and a revised record retention section for clarity and general consistency with the current banking environment.

Action Item: If your organization utilizes the BCP Policy template from BAI, please replace it with Business Continuity Management Policy.

December 11, 2023

FDIC proposes stricter governance guidelines for regional banks

The Federal Deposit Insurance Corp. issued proposed guidelines directing large banks to establish and promote risk management strategies, ethical codes and policies that ensure safe and sound operations, compliance with regulations and consumer protections. Under the proposal, the board of directors at all FDIC-supervised institutions — primarily state-chartered banks that are not part of the Federal Reserve system — with more than $10 billion of assets would need to establish risk management programs commensurate with the firm’s size, risk profile, complexity and business model. The guidance also directs applicable banks to implement what’s known as a “three-line-of-defense” risk management model to keep tabs on reporting risks. The layers of such a model would consist of risk management in banks’ business units, an independent risk management program helmed by a chief risk officer and an internal audit. The guidance further notes banks will be responsible for proactively communicating their risk appetite and maintaining a strategy for promoting compliance by their staff and reporting any breaches of their articulated risk limits.

Action Item: Banks with over $10 billion in assets should Review the proposal and submit any necessary comment.

December 13, 2023

SEC Adopts Rule to Increase Transparency in the Securities Lending Market

The Securities and Exchange Commission adopted new Rule 10c-1a, which will require certain persons to report information about securities loans to a registered national securities association (RNSA) and require RNSAs to make publicly available certain information that they receive regarding those lending transactions. The rule is intended to increase the transparency and efficiency of the securities lending market. Rule 10c-1a will require certain confidential information to be reported to an RNSA to enhance the RNSA’s oversight and enforcement functions. Further, the new rule requires that an RNSA make certain information it receives, along with daily information pertaining to the aggregate transaction activity and distribution of loan rates for each reportable security, available to the public.

Action Item: Publicly traded companies should review the final rule and develop an understanding about the content and timing requirements.

December 15, 2023

FTC Proposes Rule to Ban Junk Fees

The Federal Trade Commission today announced a new proposed rule to prohibit junk fees, which are hidden and bogus fees that can harm consumers and undercut honest businesses. The FTC has estimated that these fees can cost consumers tens of billions of dollars per year in unexpected costs.

Action Item: Institutions should submit comment on the proposed rule.

Course Updates: (Release Date TBD)

BAI will release new and updated courseware upon finalization of the rule.

December 16, 2023

Regulation Z Policy Template and Policy Consideration Release

BAI has developed a Regulation Z Policy Template and Policy Consideration for it’s BAI Policy Manager clients. Both templates will be available by December 15, 2023.

Action Item: Financial institutions should review and approve the policy template.

December 18, 2023

SEC Proposes Rule to Address Volume-Based Exchange Transaction Pricing for NMS Stocks

The Securities and Exchange Commission today proposed a new rule that would prohibit national securities exchanges from offering volume-based transaction pricing in connection with the execution of agency or riskless principal (“agency-related”) orders in NMS stocks. The proposal also would require national securities exchanges to have certain anti-evasion rules and written policies and procedures and disclose certain information if they offer volume-based transaction pricing for member proprietary volume in NMS stocks. Proposed Rule 6b-1 under the Securities Exchange Act of 1934 would prohibit national securities exchanges from offering volume-based transaction pricing in connection with the execution of agency-related orders in NMS stocks. It also would require exchanges that offer volume-based transaction pricing in connection with the execution of members’ proprietary orders in NMS stocks to disclose certain information, including the number of members that qualify for each transaction pricing tier that the exchange offers.

Action Item: National securities exchanges should review the proposal and submit applicable comments.

December 22, 2023

NCUA Issues Proposals on Fair Hiring in Banking; Simplification of Share Insurance

The National Credit Union Administration Board held its ninth open meeting of 2023, where it unanimously approved a proposed rule incorporating its Second Chance Interpretive Ruling and Policy Statement and the Fair Hiring in Banking Act into its regulations. The NCUA Board also approved a proposed rule that would simplify share insurance regulations by establishing a “trust accounts” category.

Action Item: Credit unions should submit comment on the proposed rules.

Course Updates: (Release Date TBD)

30328C – Federally Insured Accounts

December 25, 2023

Comment Period Open on Simplification of Share Insurance Rules Proposed Rule

The comment period on a proposed rule that would simplify the NCUA’s share insurance regulations by establishing a “trust accounts” category is now open. The proposed rule was published in the Federal Register on October 25, and has a 60-day comment period, ending December 26. The trust accounts category would provide Share Insurance Fund coverage of funds in both revocable and irrevocable trusts deposited at federally insured credit unions in the accounts of members or those otherwise eligible to maintain insured accounts.

Action Item: Credit unions should submit comment on the proposed rules.

Course Updates: (Release Date TBD)

30328C – Federally Insured Accounts

December 26, 2023

Board Issues Final Rule on Joint-Employer Status

Under the new standard, an entity may be considered a joint employer of a group of employees if each entity has an employment relationship with the employees and they share or codetermine one or more of the employees’ essential terms and conditions of employment, which are defined exclusively as: (1) wages, benefits, and other compensation; (2) hours of work and scheduling; (3) the assignment of duties to be performed; (4) the supervision of the performance of duties; (5) work rules and directions governing the manner, means, and methods of the performance of duties and the grounds for discipline; (6) the tenure of employment, including hiring and discharge; and (7) working conditions related to the safety and health of employees.

Action Item: Institutions should determine whether any workers not previously considered employees are covered by the rule.

December 29, 2023

CFPB Proposes Rule to Jumpstart Competition and Accelerate Shift to Open Banking

The Consumer Financial Protection Bureau (CFPB) proposed a rule that would accelerate a shift toward open banking, where consumers would have control over data about their financial lives and would gain new protections against companies misusing their data. The proposed Personal Financial Data Rights rule activates a dormant provision of law enacted by Congress more than a decade ago. It would jumpstart competition by forbidding financial institutions from hoarding a person’s data and by requiring companies to share data at the person’s direction with other companies offering better products. The proposed rule would allow people to break up with banks that provide bad service and would forbid companies that receive data from misusing or wrongfully monetizing the sensitive personal financial data.

Action Item: Financial institutions should submit comment on the proposed rule.

Course Updates: (Release Date TBD)

BAI will release new and updated courseware upon finalization of the rule.

November 6, 2023

NIST Seeks Input on Implementation of National Standards Strategy for Critical and Emerging Technology

The U.S. Department of Commerce’s National Institute of Standards and Technology (NIST) has published a Request for Information seeking public input on how best to implement the U.S. Government National Standards Strategy for Critical and Emerging Technology (USG NSSCET).

Action Item: Institutions should submit comment on the proposed standards.

November 18, 2023

SEC Proposes Improvements to EDGAR Filer Access and Account Management

The Securities and Exchange Commission today proposed rule and form amendments to improve filer access to and management of accounts on the SEC’s EDGAR system. The proposed amendments would require EDGAR filers to authorize identified individuals who would be responsible for managing filers’ EDGAR accounts. In addition, individuals acting on behalf of filers on EDGAR would need individual account credentials to access those EDGAR accounts and make filings. If the proposed amendments are later adopted, the SEC will make technical changes to EDGAR, including to make available to EDGAR filers certain Application Programming Interfaces (APIs) for machine-to-machine submissions on EDGAR and retrieval of related filing information. The SEC today also announced that it will open to the public a beta software environment for filer testing and feedback, which will reflect the proposed rule and form amendments and the related technical changes, on Sept. 18, 2023.

Action Item: Publicly traded companies should review the proposals and submit comment.

October 1, 2023

Federal Reserve Board announces the individual capital requirements for all large banks

The Federal Reserve Board today announced the individual capital requirements for all large banks, effective on October 1. Large bank capital requirements are in part determined by the Board’s stress test results, which provide a risk-sensitive and forward-looking assessment of capital needs. The table shows each bank’s total common equity tier 1 capital requirement, which is made up of several components, including: The minimum capital requirement, which is the same for each firm and is 4.5 percent; The stress capital buffer requirement, which is determined from the stress test results, and is at least 2.5 percent; and If applicable, a capital surcharge for global systemically important banks (G-SIBs), which is updated in the first quarter of each year to account for the overall systemic risk of each G-SIB. If a bank’s capital dips below its total requirement announced today, the bank is subject to automatic restrictions on both capital distributions and discretionary bonus payments. The Board received no requests for reconsideration from any bank.

Action Item: Large banks should review the capital requirements and adjust their policies to ensure they will meet the capital requirements by the effective date.

October 10, 2023

OCC Requests Comment for Survey on Trust in Banking

The OCC invites interested members of the public, including financial industry participants, other government agencies, academic and research organizations, consumer advocacy and financial education organizations, trade associations, and financial services customers, to comment on the scope of the survey, components and drivers of trust, and ways to track and assess trust over time. Responding to the survey is voluntary.

Action Item: Financial institutions should submit comment on the survey.

October 25, 2023

NCUA Board Approves Final Rule on Financial Innovation

The NCUA Board approved a financial innovation final rule that clarifies the NCUA’s current regulations and provides flexibility for federally insured credit unions to take advantage of advanced technologies and opportunities offered by the financial technology sector.

Action Item: Credit unions should review the final rule and perform a risk assessment on whether expanding into indirect lending and other financial innovations is appropriate.

September 1, 2023

NCUA Board Approves Final Rule on Cyber Incident Reporting Requirements

Under the final rule, federally insured credit unions are required to report a cyber incident that leads to a substantial loss of confidentiality, integrity, or availability of a network or member information system as a result of the exposure of sensitive data, disruption of vital member services, or that has a serious impact on the safety and resiliency of operational systems and processes. Additionally, cyberattacks that disrupt a credit union’s business operations, vital member services, or a member information system must be reported to the NCUA within 72 hours of a credit union’s reasonable belief that it has experienced a cyberattack.

Action Item: Federally insured credit unions should update cybersecurity policies to reflect the new reporting requirements and train the relevant personnel.

Course Updates: (Release Date April 4, 2023)

• 4105C – Cybersecurity Incident Notification Requirements

September 12, 2023

SEC Adopts Money Market Fund Reforms and Amendments to Form PF Reporting Requirements for Large Liquidity Fund Advisers

The amendments will increase minimum liquidity requirements for money market funds to provide a more substantial liquidity buffer in the event of rapid redemptions. The amendments will also remove provisions in the current rule that permit a money market fund to suspend redemptions temporarily through a gate and allow money market funds to impose liquidity fees if their weekly liquid assets fall below a certain threshold. These changes are designed to reduce the risk of investor runs on money market funds during periods of market stress. To address concerns about redemption costs and liquidity, the amendments will require institutional prime and institutional tax-exempt money market funds to impose liquidity fees when a fund experiences daily net redemptions that exceed 5 percent of net assets, unless the fund’s liquidity costs are de minimis. In addition, the amendments will require any non-government money market fund to impose a discretionary liquidity fee if the board determines that a fee is in the best interest of the fund. These amendments are designed to protect remaining shareholders from dilution and to more fairly allocate costs so that redeeming shareholders bear the costs of redeeming from the fund when liquidity in underlying short-term funding markets is costly. Separately, the amendments will also modify certain reporting forms that are applicable to money market funds and large private liquidity funds advisers.

Action Item: Large liquidity fund advisors should review the amendments to identify the specific requirements, and updates policies, procedures, and reporting forms according to the terms and effective dates, and issue a communication to the effected staff to make them aware of the upcoming changes.

September 15, 2023

FHFA Issues Notice of Proposed Rulemaking on the Suspended Counterparty Program

Specifically, the proposed rule would authorize the suspension of business between the regulated entities and counterparties who are found to have committed misconduct in the context of civil enforcement actions or who are found to have committed criminal or civil misconduct in connection with the management or ownership of real property. In addition, the rule would authorize FHFA to, immediately and without first issuing a proposed suspension order, suspend business between the regulated entities and counterparties where the misconduct has resulted in debarment, suspension, or limited denial of participation imposed by a federal agency.

Action Item: Entities regulated by the FHFA should submit comment on the proposed rule.

September 18, 2023

FTC and DOJ Seek Comment on Draft Merger Guidelines

Today, the Federal Trade Commission and the Department of Justice are releasing a draft update of the Merger Guidelines, which describe and guide the agencies’ review of mergers and acquisitions to determine compliance with federal antitrust laws. The goal of this update is to better reflect how the agencies determine a merger’s effect on competition in the modern economy and evaluate proposed mergers under the law. Both agencies encourage the public to review the draft and provide feedback through a public comment period that will last 60 days.

Action Item: Financial institutions should submit comment on the proposed guidelines.

September 26, 2023

SEC Proposes New Requirements to Address Risks to Investors From Conflicts of Interest Associated With the Use of Predictive Data Analytics

The Securities and Exchange Commission proposed new rules that would require broker-dealers and investment advisers (collectively, “firms”) to take certain steps to address conflicts of interest associated with their use of predictive data analytics and similar technologies to interact with investors to prevent firms from placing their interests ahead of investors’ interests.

Action Item: Broker-dealers and investment advisors should submit comment on the proposed rule.

SEC Proposes Reforms Relating to Investment Advisers Operating Exclusively Through the Internet

The Securities and Exchange Commission proposed amendments to the rule permitting certain investment advisers that provide investment advisory services through the internet to register with the Commission. The proposed amendments generally would require an investment adviser relying on the internet adviser registration rule to have at all times an operational interactive website through which the adviser provides digital investment advisory services on an ongoing basis to more than one client. The proposed amendments would also eliminate the de minimis exception from the current rule by proposing to require that an internet investment adviser provide advice to all of its clients exclusively through an operational interactive website, and make certain corresponding changes to Form ADV.

Action Item: Investment advisors should submit comment on the proposed rule.

September 30, 2023

SBA Announces Extension of Moratorium on 8(a) Eligibility Requirement

The SBA extended the 8(a) Business Development Bona Fide Place of Business (BFPOB) Requirement Moratorium through September 30, 2024. The moratorium was created in 2021 as a response to the COVID-19 pandemic and remote work conditions in the marketplace so participants in the SBA’s 8(a) Business Development Program could forgo the requirement of having an established physical presence in a particular location to be awarded any construction contract through the 8(a) Program.

August 4, 2023

Agencies Request Comment on Quality Control Standards for Automated Valuation Models Proposed Rule

Six federal regulatory agencies today requested public comment on a proposed rule designed to ensure the credibility and integrity of models used in real estate valuations. In particular, the proposed rule would implement quality control standards for automated valuation models (AVMs) used by mortgage originators and secondary market issuers in valuing real estate collateral securing mortgage loans.

Action Item: Mortgage lenders and appraisers that use automated valuation models should submit comment on the proposed rule.

Course Updates: (Release Date TBD)

30411B / 30411C / 30411M / 30411N – Appraisals and Evaluations: Essentials

30412B / 30412C / 30412M / 30412N – Appraisals and Evaluations: Comprehensive

August 11, 2023

SEC Adopts Rules to Prevent Fraud in Connection with Security-Based Swaps Transactions and Prevent Undue Influence over CCOs

The Securities and Exchange Commission today adopted rules to prevent fraud, manipulation, and deception in connection with security-based swap transactions and to prevent undue influence over the chief compliance officer (CCO) of security-based swap dealers and major security-based swap participants (SBS Entities).

Action Item: SBS entities should review the rule and adjust ethics policies accordingly.

August 11, 2023

Agencies Propose Interagency Guidance on Reconsiderations of Value for Residential Real Estate Valuations

Five federal regulatory agencies today requested public comment on proposed guidance addressing reconsiderations of value (ROV) for residential real estate transactions. The proposed guidance advises on policies that financial institutions may implement to allow consumers to provide financial institutions with information that may not have been considered during an appraisal or if deficiencies are identified in the original appraisal. ROVs are requests from a financial institution to an appraiser or other preparer of a valuation report to reassess the value of residential real estate. An ROV may be warranted if a consumer provides information to a financial institution about potential deficiencies or other information that may affect the estimated value.

Action Item: Mortgage lenders should submit comment on the proposed guidance.

Commission Seeks Public Comment on Collaboration with State Attorneys General

The Federal Trade Commission is seeking public comments and suggestions on ways it can work more effectively with state attorneys general nationwide to help educate consumers about, and protect them from, potential fraud. The request for public information (RFI) announced today comes at the direction of the FTC Collaboration Act of 2021, which President Biden signed into law last October.

Action Item: Financial institutions should submit comment on the proposed rule.

August 14, 2023

FHFA Requests Input on the Enterprises’ Single-Family Pricing Framework

The Federal Housing Finance Agency (FHFA) issued a Request for Input (RFI) on Fannie Mae and Freddie Mac’s (the Enterprises) single-family pricing framework. The RFI solicits public feedback on the goals and policy priorities that FHFA should pursue in its oversight of the pricing framework.

Action Item: Mortgage lenders that provide single-family mortgages should submit comment on the proposed rule.

August 16, 2023

HUD Seeks Public Input to Enhance Accessibility and Usability of Programs

HUD has taken a number of recent actions to streamline and improve its programs and advance the Biden-Harris administration’s priorities to protect renters and boost housing supply. Several efforts were highlighted earlier this week in a White House report to Congress, including streamlined income verification processes in public housing and multifamily programs. Today’s announcement gives the public an opportunity to inform HUD’s plans and actions to further reduce burdens and increase access to its programs going forward.

Action Item: Mortgage lenders and mortgage servicers should submit comment to HUD.

SEC Proposes Rule Amendments to the Broker-Dealer Customer Protection Rule

The Securities and Exchange Commission today proposed amendments to Rule 15c3-3 (the Customer Protection Rule) to require certain broker-dealers to increase the frequency with which they perform computations of the net cash they owe to customers and other broker-dealers (known as PAB account holders) from weekly to daily. Net cash owed to customers and PAB account holders must be held in a special reserve bank account.

Action Item: Broker-dealers should submit comment on the proposed rule.

August 21, 2023

SEC Reopens Comment Period for Position Reporting of Large Security-Based Swap Positions

The Securities and Exchange Commission today reopened the comment period for its proposed rule for position reporting of large security-based swap positions that exceed certain thresholds, and the staff of the Commission’s Division of Economic and Risk Analysis released a memorandum that provides supplemental data and analysis regarding the proposed reporting thresholds in the equity security-based swap market.

Action Item: Financial institutions that deal in securities and security-based swaps should submit comment on the proposed rule.

FTC Seeks Comment on New Parental Consent Mechanism Under COPPA

Under the COPPA Rule, online sites and services directed to children under 13 must obtain parental consent before collecting or using personal information from a child. The Rule lays out a number of acceptable methods for gaining parental consent but also includes a provision allowing interested parties to submit new verifiable parental consent methods to the Commission for approval.

Action Item: Institutions that provide youth deposit accounts should submit comment on the rule.

August 23, 2023

NCUA Board Approves Final Member Expulsion Rule

The NCUA Board unanimously approved a final rule (opens new window) that amends the standard federal credit union bylaws to adopt a policy by which a federal credit union member may be expelled for cause by a two-thirds vote of a quorum of the credit union’s board of directors.

Action Item: Federal credit unions develop a policy outlining the process for expelling a member for cause.

Course Updates: (Release Date TBD)

BAI will release a new course presently.

July 1, 2023

Federal Reserve Board finalizes updates to the Board’s rule concerning debit card transactions

The Federal Reserve Board on Monday finalized updates to the Board’s rule concerning debit card transactions. Pursuant to statute, the updates specify that debit card issuers should enable at least two payment card networks to process all debit card transactions, including “card-not-present” transactions, such as online payments. The final rule is substantially similar to the proposal issued last year.

Course Updates: (Release Date November 22, 2022)

30212B / 30212C / 30212N – Reg II: How Interchange Fees Affect Your Institution

Attorney General Becerra Announces Approval of Additional Regulations That Empower Data Privacy Under the California Consumer Privacy Act

California Attorney General Xavier Becerra today announced additional regulations approved by the Office of Administrative Law that advance protections for Californians seeking to control the sale of their personal information. The California Consumer Privacy Act (CCPA) gives consumers new tools and rights for protecting their data privacy. These newly-approved rules strengthen the language of the CCPA regulations approved by OAL in August 2020, including protecting consumers from unlawful business practices that may be deceptive or misleading.

Course Updates: (Release Date TBD)

BAI will release new courseware closer to the effective date of the rule.

SEC Adopts Rules to Enhance Proxy Voting Disclosure by Registered Investment Funds and Require Disclosure of “Say-on-Pay” Votes for Institutional Investment Managers

The Securities and Exchange Commission today adopted amendments to Form N-PX to enhance the information mutual funds, exchange-traded funds, and certain other registered funds report about their proxy votes. The amendments will make these funds’ proxy voting records more usable and easier to analyze, improving investors’ ability to monitor how their funds vote and compare different funds’ voting records. The rulemaking will also newly require institutional investment managers to disclose how they voted on executive compensation, or so-called “say-on-pay” matters, which fulfills one of the remaining rulemaking mandates under the Dodd-Frank Wall Street Reform and Consumer Protection Act.

Action Item: Institutional investment managers that offer Institutional Investment Manager-mutual funds, exchange-traded funds, and certain other registered funds should implement the new voter proxy records.

Federal Reserve Board finalizes updates to the Board’s rule concerning debit card transactions

The Federal Reserve Board on Monday finalized updates to the Board’s rule concerning debit card transactions. Pursuant to statute, the updates specify that debit card issuers should enable at least two payment card networks to process all debit card transactions, including “card-not-present” transactions, such as online payments. The final rule is substantially similar to the proposal issued last year.

Course Updates: (Release Date November 22, 2022)

30212B / 30212C / 30212N – Reg II: How Interchange Fees Affect Your Institution

July 12, 2023

FCC Proposes to Strengthen Consumers’ Robocall & Robotext Rights

 

Initiates a proceeding to clarify and strengthen consumers’ ability to revoke consent to receive both robocalls and robotexts. Doing so will also clarify callers’ obligations under the Commission’s rules to honor such requests in a timely manner.

Action Item: Financial institutions should submit comment on the proposed rule.

July 26, 2023

CFPB Proposes New Consumer Protections for Homeowners Seeking Clean Energy Financing

The Consumer Financial Protection Bureau (CFPB) proposed a rule to implement a Congressional mandate to establish consumer protections for residential Property Assessed Clean Energy (PACE) loans. PACE loans, secured by a property tax lien on the borrower’s home, are often promoted as a way to finance clean energy improvements such as solar panels. The proposed rule would require lenders to assess a borrower’s ability to repay a PACE loan and would provide a framework for how these loans will be treated under the Truth in Lending Act. The CFPB also published a report on residential PACE loans, which found that the loans cause an increase in borrowers falling behind on their mortgage payments, along with other negative credit outcomes.

Action Item: Consumer lenders who provide PACE loans should submit comment on the proposed rule.

July 31, 2023

FHFA Requests Input on Multifamily Tenant Protections

​FHFA took a number of actions that provided multifamily tenant protections and support for multifamily property owners during the COVID-19 national emergency.  FHFA’s decision to evaluate the Enterprises’ multifamily tenant standards is based on lessons learned from COVID-19, rising rents, and a shortage of safe and affordable housing in America.

Action Item: Servicers of multifamily mortgages should submit comment to the FHFA.

June 9, 2023

FTC Extends Deadline by Six Months for Compliance with Some Changes to Financial Data Security Rule

The Federal Trade Commission today announced it is extending by six months the deadline for companies to comply with some of the changes the agency implemented to strengthen the data security safeguards financial institutions must put in place to protect their customers’ personal information. The deadline for complying with some of the updated requirements of the Safeguards Rule is now June 9, 2023.

Action Item: Financial institutions that offer consumer products should continue to implement data security policies for complying with the Safeguards Rule

Course Updates: (Release Date TBD)

BAI is releasing a new course to cover this rule.

June 12, 2023

FinCEN Requests Comments on Renewal of the OMB Control Number for the Registration of Money Services Businesses (RMSB) Regulations and FinCEN Form 107

The Financial Crimes Enforcement Network (FinCEN) published in the Federal Register a 60-day notice to renew the Office of Management and Budget (OMB) control number assigned to existing Bank Secrecy Act regulations at 31 CFR 1022.380 and FinCEN Form 107 (RMSB). Specifically, the regulations require money services businesses to register with FinCEN using FinCEN Form 107, renew their registration every two years, and maintain a list of their agents. The notice is required to give the public an opportunity to comment on existing regulatory requirements and burden estimates. The notice requests feedback from industry on or before June 12, 2023. FinCEN encourages the public to review this notice and provide comment.

Action Item: Financial institutions that provide account relationships for money services businesses should submit comment to FinCEN.

June 14, 2023

SEC Reopens Comment Period for Proposed Amendments to Exchange Act Rule 3b-16 and Provides Supplemental Information

The reopening release reiterated the applicability of existing rules to platforms that trade crypto asset securities, including so-called “DeFi” systems, and provides supplemental information and economic analysis for systems that would be included in the new, proposed exchange definition. The reopening release also requested information and public comment on crypto asset securities trading on such systems and certain aspects of the proposed amendments applicable to all securities.

Action Item: Financial institutions that provide account relationships for crypto-exchanges should submit comment to the SEC.

June 19, 2023

FHFA Issues Notice of Proposed Rulemaking on Fair Lending Oversight

The Federal Housing Finance Agency (FHFA) announced that it is seeking comment on a proposed rule that would formalize many of the Agency’s existing practices and programs regarding fair housing and fair lending oversight of its regulated entities. Specifically, the proposed rule would codify in regulation: FHFA’s fair lending oversight requirements for Fannie Mae and Freddie Mac (the Enterprises) and the Federal Home Loan Banks (Banks); the requirements for the Enterprises to maintain Equitable Housing Finance Plans; and ​​the requirements for the Enterprises to collect and report homeownership education, housing counseling, and language preference information from the Supplemental Consumer Information Form (SCIF). The rule would also expand requirements for the Enterprises in fair lending compliance and provide greater oversight and transparency regarding the Equitable Housing Finance Plans.

Action Item: Financial institutions involved in the secondary mortgage market should submit comment to the FHFA.

June 30, 2023

Federal Reserve Adopts Rule Implementing Adjustable Interest Rate (LIBOR) Act

The Federal Reserve Board on Friday adopted a final rule that implements the Adjustable Interest Rate (LIBOR) Act by identifying benchmark rates based on SOFR (Secured Overnight Financing Rate) that will replace LIBOR in certain financial contracts after June 30, 2023. The final rule is substantially similar to the proposal with certain clarifying changes made in response to comments.

Action Item: Institutions that utilize LIBOR in financial contracts should identify financial contracts that utilize LIBOR and modify them to reflect the new SOFR benchmark.

June 30, 2023

Federal Housing Administration Proposes Innovative Approach to Keep Struggling Homeowners in their Homes

Today, the Federal Housing Administration (FHA) posted for feedback a proposal for a new home retention option to help struggling homeowners meet their mortgage obligations. The new option, called the Payment Supplement Partial Claim, would allow mortgage servicers to use the FHA Partial Claim both to bring a borrower’s mortgage current and to provide temporary reductions to their monthly mortgage payments for up to five years.

Action Item: Mortgage servicers should submit comment on the proposed rule.

Course Updates: (Release Date TBD)

32004B / 32004C / 32004M / 32004N – Mortgage Servicing: Loss Mitigation and Foreclosure

May 15, 2023  |  COMMENTS DUE

State Regulators Seek Public Comment on Proposed Mortgage Industry Licensing Standards

CSBS announced a public comment period for proposed uniform state licensing standards for mortgage companies. “Adopting a standardized approach for mortgage industry licensing will help increase uniformity within the state system,” said Vickie Peck, CSBS executive vice president of products and solutions. “In turn, uniform standards will streamline the licensing process for mortgage companies seeking licensure in multiple states,” added Peck.

Action Item: State chartered banks should provide comments on the proposal before the comment period expires.

May 16, 2023  |  COMMENTS DUE

FTC Launches Inquiry into Small Business Credit Reports

The Federal Trade Commission has launched an inquiry into the small business credit reporting industry, ordering five firms in that industry to provide the Commission with detailed information about their products and processes. The orders will be issued to Dun & Bradstreet, Experian Information Solutions, Equifax, Ansonia Credit Data, and Creditsafe USA. These reports can significantly affect small businesses, potentially impacting the terms on which they can obtain the goods, services, and equipment they need to stay in business. Because many of these credit reporting companies start developing a company’s credit report at the time it incorporates, tapping public records and other available financial data, business owners may not even be aware a report about them exists. Sometimes small businesses only discover they have a credit report when they are denied credit by a supplier. The Commission’s inquiry will examine multiple aspects of how information is collected and processed for business credit reports, how the reports are marketed, and how and whether the credit reporting companies address factual errors in the reports. In addition to information about these topics, the orders also require the companies to provide information on services they provide to businesses to monitor or enhance their own credit reports.

Action Item: Financial institutions should provide comments on the proposal before the comment period expires.

May 22, 2023  |  COMMENTS DUE

FTC Seeks Comment on Business Practices of Cloud Computing Providers that Could Impact Competition and Data Security

The Federal Trade Commission staff are seeking information on the business practices of cloud computing providers including issues related to the market power of these companies, impact on competition, and potential security risks. In a Request for Information, FTC staff are seeking information about the competitive dynamics of cloud computing, the extent to which certain segments of the economy are reliant on cloud service providers, and the security risks associated with the industry’s business practices. In addition to the potential impact on competition and data security, FTC staff are also interested in the impact of cloud computing on specific industries including healthcare, finance, transportation, e-commerce, and defense.

Action Item: Financial institutions should provide information on the business practices of cloud computing providers including issues related to the market power of these companies, impact on competition, and potential security risks.

April 3, 2023  |  COMMENTS DUE

CFPB Proposes Rule to Rein in Excessive Credit Card Late Fees

Today, the Consumer Financial Protection Bureau (CFPB) proposed a rule to curb excessive credit card late fees that cost American families about $12 billion each year. Major credit card issuers continue to profit off late fees that are protected by an expansive immunity provision. Credit card companies have also relied on this provision to hike fees with inflation, even if they face no additional collection costs. The proposed rule would help ensure that over the top late fee amounts are illegal. Based on the CFPB’s estimates, the proposal could reduce late fees by as much as $9 billion per year.

Action Item: Credit card issuers should submit comments to the CFPB.

April 7, 2023  |  COMMENTS DUE

FDIC Extends Comment Period for Proposed Changes to Regulation Regarding the FDIC Official Sign

The Federal Deposit Insurance Corporation (FDIC) today announced a 45-day extension to the public comment period for proposed changes to its regulations relating to the FDIC’s official sign, the FDIC’s official advertising statement, misrepresentations of deposit insurance coverage, and misuse of the FDIC’s name or logo. Comments must be received by the FDIC no later than April 7, 2023.

Action Item: Banks should submit comments to the FDIC.

April 17, 2023  |  COMMENTS DUE

FHFA Requests Input on Enterprise Single-Family Social Bond Program

Currently, each Enterprise issues labeled multifamily social bonds—neither issues labeled single-family social bonds. This RFI will help FHFA understand the opportunities and potential risks associated with the Enterprises issuing single-family social bonds, under the framework of Environmental, Social, and Governance (ESG) securities. FHFA also seeks input in defining the criteria and appropriate impact measures for Enterprise-labeled single-family social bonds.

Action Item: Mortgage brokers and securities dealers should submit comments to the FHFA.

April 19, 2023  |  COMMENTS DUE

FTC Extends Comment Period on Its Proposed Rule to Ban Noncompete Clauses

The Federal Trade Commission voted to extend the public comment period for its proposed new rule to ban employers from imposing noncompetes on their workers. With the extension, the FTC will now be accepting comments on the proposed rule until April 19. Originally, the deadline for submitting comments was March 20.

Action Item: Institutions should submit comment to the FTC.

April 24, 2023  |  COMMENTS DUE

CFPB Seeks Public Input on Consumer Credit Card Market

The Consumer Financial Protection Bureau (CFPB) issued a request for information today seeking public feedback on how the consumer credit market is functioning as part of a biennial review of the industry. The CFPB is seeking more and current information on various aspects of the consumer experience with credit cards. Congress enacted the Credit Card Accountability Responsibility and Disclosure Act of 2009 (CARD Act) to establish fair and transparent practices related to the extension of credit in the credit card market. The CARD Act mandates the CFPB to conduct a review of the credit card industry every two years and report to Congress.

Action Item: Credit card issuers should submit their comments on the credit card market to the CFPB.

June 30,  2024

Federal judge delays Section 1071 compliance dates; temporary relief applies only to ABA, TBA members

A federal judge in Texas issued an order blocking enforcement of the Consumer Financial Protection Bureau’s Section 1071 final rule while the Supreme Court hears a challenge to the constitutionality of the CFPB’s funding structure. While the judge granted ABA and TBA’s request for an injunction, the judge did not accept ABA’s and TBA’s request for the injunction to apply to all lenders covered by the rule but chose to provide relief only to TBA and ABA member banks across the country. The relief applies while the Supreme Court hears the constitutional challenge to the CFPB in CFPB v. Community Financial Services Association of America, which is scheduled to be argued in October and whose decision could be released any time before the end of June 2024, at which point new compliance deadlines would be issued for ABA and TBA members. “Defendants are ordered to extend Plaintiffs and their members’ deadlines for compliance with the requirements of the Final Rule to compensate for the period stayed,” the judge’s order said. The ruling would thus allow ABA and TBA members to limit Section 1071 implementation costs until the question of the CFPB’s constitutionality is resolved.

Course Updates: (Release Date TBD)

30260B / 30260C / 30260N – The Small Business Lending Rule

Action Item: Members of the ABA and TBA should continue to understand the requirements under Section 1071, but pay be aware of the Supreme Court’s decision on the lawsuit, which is expected to be release in the middle of 2024.

All other applicable financial institutions should continue to implement the requirements and plan on fully complying by the applicable effective date.

April 1, 2024

CFPB Proposes Rule to Close Bank Overdraft Loophole that Costs Americans Billions Each Year in Junk Fees

The Consumer Financial Protection Bureau (CFPB) today proposed a rule  to rein in excessive overdraft fees charged by the nation’s biggest financial institutions. The proposal would close an outdated loophole that exempts overdraft lending services from longstanding provisions of the Truth in Lending Act and other consumer financial protection laws. Essentially, the proposal would cap fees for banks and credit unions with more than $10 billion in assets. Banks with assets of less than $10 billion would be exempt. Under the proposal, large banks would be free to extend overdraft loans if they complied with longstanding lending laws, including disclosing any applicable interest rate. Alternatively, banks could charge a fee to recoup their costs at an established benchmark – as low as $3, or at a cost they calculate, if they show their cost data. The CFPB has proposed benchmarks of $3, $6, $7, or $14 and is seeking comment on the appropriate amount.

Action Item: Depository institutions should submit comment on the proposed rule.

Course Updates: (Release Date TBD)

BAI will release new and updated courses upon finalization of the rule.

April 13, 2024

FinCEN Proposes Rule to Combat Money Laundering and Promote Transparency in Residential Real Estate

The proposed rule would require certain professionals involved in real estate closings and settlements to report information to FinCEN about non-financed transfers of residential real estate to legal entities or trusts. FinCEN’s proposal is tailored to target residential real estate transfers considered to be high-risk for money laundering, while minimizing potential business burden, and it would not require reporting of transfers made to individuals.

Action Item: Real estate professionals should submit comment on the proposed rule.

Course Updates: (Release Date TBD)

BAI will release new and updated courses upon finalization of the rule.

April 14, 2024

FinCEN Proposes Rule to Combat Illicit Finance and National Security Threats in Investment Adviser Sector

Today, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued a Notice of Proposed Rulemaking (NPRM) to keep criminals and foreign adversaries from exploiting the U.S. financial system and assets through investment advisers. This proposed rule, which complements Treasury’s other recent actions to combat the illicit finance risks from anonymous companies and all-cash real estate transactions, will add further transparency to the U.S. financial system and help assist law enforcement in identifying illicit proceeds entering the U.S. economy.

Action Item: Financial advisors should submit comment on the proposed rule.

Course Updates: (Release Date TBD)

BAI will release new and updated courses upon finalization of the rule.

April 20, 2024

FTC Proposes New Protections to Combat AI Impersonation of Individuals

The Federal Trade Commission is seeking public comment on a supplemental notice of proposed rulemaking that would prohibit the impersonation of individuals. The proposed rule changes would extend protections of the new rule on government and business impersonation that is being finalized by the Commission today.

Action Item: Financial institutions should submit comment on the proposed rule.

May 12, 2024

Federal Reserve Extends the Comment Period on Interchange Fee Proposal

Interchange fees are paid by merchants and received by debit card issuers for each debit card transaction. In October 2023, the Board requested comment on a proposal to lower the maximum interchange fee that a large debit card issuer can receive for a debit card transaction. The proposal would also establish a regular process for updating the maximum amount every other year going forward. By law, the Board is required to establish standards for assessing whether an interchange fee received by a large debit card issuer for processing a debit card transaction is reasonable and proportional to certain issuer costs.

Action Item: Debit card issuers should submit comment on the proposed rule.

Course Updates: (Release Date TBD)

30212B / 30212C / 30212N – Reg II: How Interchange Fees Affect Your Institution

Federal Bank Regulatory Agencies Seek Comment on Interagency Effort to Reduce Regulatory Burden

The federal bank regulatory agencies today published their first of a series of requests for comment to reduce regulatory burden. The Economic Growth and Regulatory Paperwork Reduction Act of 1996 requires the Federal Financial Institutions Examination Council and federal bank regulatory agencies to review their regulations every 10 years to identify any outdated or otherwise unnecessary regulatory requirements for their supervised institutions.

Action Item: Financial institutions should submit comment to their federal regulators.

May 24, 2024

FDIC Seeks Public Comment on Proposed Revisions to its Statement of Policy on Bank Merger Transactions

The revised SOP reflects legislative and other developments that have occurred since it was last amended in 2008, including the establishment of the statutory factor regarding the risk to the stability of the United States banking or financial system.  The revised SOP is principles based; describes the types of applications subject to FDIC approval; addresses each statutory factor separately; and highlights other relevant matters and considerations, such as related statutes pertaining to interstate mergers, and applications from non-banks or banks that are not traditional community banks.  Further, the revised SOP reflects consideration of comment letters received in response to the FDIC’s March 2022 Request for Information and Comment on Rules, Regulations, Guidance, and Statements of Policy Regarding Bank Merger Transactions.

Action Item: Banks regulated by the FDIC should submit comment on the proposed SOP.

June 1, 2024

FinCEN Seeks Comments on Customer Identification Program Requirement

The U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) is issuing a request for information (RFI) related to existing requirements for banks under the Customer Identification Program (CIP) Rule to collect a taxpayer identification number (TIN) from a customer prior to opening an account. Generally, for a customer who is an individual and a U.S. person, banks are required to collect a full Social Security number (SSN) from a customer. The RFI is being issued in consultation with staff at the Office of the Comptroller of the Currency, the Federal Deposit Insurance Corporation, the National Credit Union Administration, and the Board of Governors of the Federal Reserve System.

Action Item: Financial institutions should submit comment to FinCEN.

Course Updates: (Release Date TBD)

4000B / 4000C / 4000M / 4000N – CIP: CDD and Beneficial Ownership
30323B / 30323C / 30323M / 30323N – CIP Procedures and Protections
30501B / 30501C / 30501M / 30501N – BSA and AML: Comprehensive
30502B / 30502C / 30502M / 30502N – BSA and AML: Essentials
31104B / 31104C / 31104N – Frontline: CIP and FCRA for Opening Deposit Accounts
31136B / 31136C / 31136N – Frontline: BSA and AML

September 1, 2024

SEC Adopts Rules for the Registration and Regulation of Security-Based Swap Execution Facilities

The Securities and Exchange Commission today adopted new Regulation SE under the Securities Exchange Act of 1934 to create a regime for the registration and regulation of security-based swap execution facilities (SBSEFs). The new regulatory framework was required under Title VII of the Dodd-Frank Wall Street Reform and Consumer Protection Act relating to the over-the-counter derivatives market. The adoption addresses the Exchange Act’s trade execution requirement for security-based swaps and the cross-border application of that requirement, implements Section 765 of the Dodd-Frank Act to mitigate conflicts of interest at SBSEFs and national securities exchanges that trade security-based swaps, and promotes consistency between Regulation SE and existing rules under the Exchange Act. In adopting Regulation SE, the Commission has sought to harmonize as closely as practicable with parallel rules of the CFTC that govern swap execution facilities (SEFs) and swap execution generally. The adopted rules will become effective 60 days following the date of publication in the Federal Register. Any entity that meets the definition of SBSEF may file an application to register with the Commission on Form SBSEF at any time after the effective date, and would need to do so within 180 days of the effective date and have its application on Form SBSEF be complete within 240 days of the effective date in order to continue to operate as an SBSEF while its application is pending.

Action Item: Any entity that meets the definition of SBSEF may file an application to register with the Commission on Form SBSEF at any time after the effective date, and would need to do so within 180 days of the effective date and have its application on Form SBSEF be complete within 240 days of the effective date in order to continue to operate as an SBSEF while its application is pending.

September 30, 2024

SEC Adopts Amendments to Rules Governing Beneficial Ownership Reporting

The Securities and Exchange Commission adopted rule amendments governing beneficial ownership reporting under Sections 13(d) and 13(g) of the Securities Exchange Act of 1934. The amendments update Regulation 13D-G to require market participants to provide more timely information on their positions to meet the needs of investors in today’s financial markets.

Action Item: Publicly traded companies should familiarize themselves with the amendments, including the content and timing disclosure requirements.

March 31, 2025

SEC Adopts Reforms Relating to Investment Advisers Operating Exclusively Through the Internet

The Securities and Exchange Commission today adopted amendments to the rule permitting certain internet investment advisers to register with the Commission (the “internet adviser exemption”). The amendments will require an investment adviser relying on the internet adviser exemption to have at all times an operational interactive website through which the adviser provides digital investment advisory services on an ongoing basis to more than one client. The amendments will also eliminate the current rule’s de minimis exception by requiring an internet investment adviser to provide advice to all of its clients exclusively through an operational interactive website and to make certain corresponding changes to Form ADV.

Action Item: Investment advisors who fall under the definition of an “internet investment advisor” must comply with the rule’s requirements by March 31, 2025.

January 1, 2026

Community Reinvestment Act: Interagency Final Rulemaking to Implement the CRA

To promote clarity and consistency, the agencies extended the applicability date of the facility-based assessment areas and public file provisions from April 1, 2024, to January 1, 2026. Therefore, banks will not have to make changes to their assessment areas or their public files as a result of the 2023 CRA final rule until January 1, 2026. This extension aligns these provisions with other substantive parts of the 2023 CRA final rule that are applicable on January 1, 2026. For example, all provisions about where banks are evaluated will now apply on the same date. Comments on the extended applicability date must be received 45 days after the rule is published in the Federal Register.

Action Item: All banks should review the final rule and update policies, procedures, and processes to comply with the new rules according to the applicable effective dates. Also, they should provide training to all applicable staff.

Course Updates: (Release Date February 29, 2024)

30405B – Community Reinvestment Act (CRA): Essentials
30406B – Community Reinvestment Act (CRA): Comprehensive
31608B – Executive Leadership: Community Responsibility
31708B – Compliance Officer: CRA Examination Management