Regulatory Alerts
Stay informed of all regulatory changes, regardless of stage! Receive the latest Financial Services industry compliance news every week, including summaries of relevant announcements from more than 20 different regulatory bodies and overviews of personnel and products affected. Focusing on the changes that may impact your training and policy management programs our service covers the following agencies and more. The list below includes the most recent regulatory alerts from the past month:
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.
Issue Date: 3/21/2024
Comments Due: 5/24/2024
Agencies Extend Applicability Date of Certain Provisions of their Community Reinvestment Act Final Rule
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.
Issue Date: 3/21/2024
Effective Date: 1/1/2026
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.
Issue Date: 3/5/2024
Effective Date: 5/5/2024
NLRB’s Joint-Employer Rule Vacated by U.S. District Judge
On Friday evening, U.S. District Judge J. Campbell Barker of the Eastern District of Texas vacated the National Labor Relations Board’s recent rule on determining the standard for joint-employer status and the Board’s rescission of the 2020 joint-employer rule. Judge Barker had previously stayed the joint-employer rule until March 11, 2024.
Issue Date: 3/9/2024
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.
Issue Date: 3/8/2024
Effective Date: 6/9/2024
CFPB Issues Guidance to Rein in Rigged Comparison-Shopping Results for Credit Cards and Other Financial Products
The Consumer Financial Protection Bureau (CFPB) today issued a circular to law enforcement agencies and regulators explaining how companies operating comparison-shopping tools can break the law when they steer consumers to certain products or lenders because of kickbacks. Consumers use comparison-shopping tools to evaluate the costs, features, and terms of many financial products, including credit cards, loans, and bank accounts. However, consumers often encounter manipulated results or digital dark patterns, fueled by behind-the-scenes incentive payments from lenders. The circular explains how these practices may violate federal law and highlights examples of illegal arrangements.
Issue Date: 2/29/2024
Safety Program Policy and Policy Considerations Updates
This policy template was revised on February 15, 2024, in response to the modification of existing regulatory guidance for additional clarity, and current industry best practices. The policy considerations will have more details on what sections/topics were specifically changed.
Issue Date: 2/15/2024
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.
Issue Date: 2/13/2024
Comments Due: 4/15/2024
The Federal Financial Institutions Examination Council today issued a statement of principles related to valuation discrimination and bias for member entities to consider in their consumer compliance and safety and soundness examinations. The principles aid member entities in assessing whether their supervised institutions’ compliance and risk management practices are appropriate to identify and mitigate discrimination or bias in their residential property valuation practices.
Issue Date: 2/12/2024
The Consumer Financial Protection Bureau (CFPB) issued a procedural rule updating the process by which financial institutions can appeal supervisory findings. The updated rule broadens the CFPB officials eligible to evaluate appeals, the options for resolving an appeal, the matters subject to appeal, and makes additional clarifying changes.
Issue Date: 2/16/2024
Effective Date: 2/20/2024
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.
Issue Date: 2/5/2024
Effective Date: 4/6/2024
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.
Issue Date: 2/8/2024
Effective Date: 3/26/2024
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.
Issue Date: 2/7/2024
Comments Due: 4/13/2024
Today the Federal Communications Commission announced the unanimous adoption of a Declaratory Ruling that recognizes calls made with AI-generated voices are “artificial” under the Telephone Consumer Protection Act (TCPA). The ruling, which takes effect immediately, makes voice cloning technology used in common robocall scams targeting consumers illegal. This would give State Attorneys General across the country new tools to go after bad actors behind these nefarious robocalls
Issue Date: 2/8/2024
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.
Issue Date: 2/6/2024
Comments Due: 5/12/2024
OCC Requests Comments on Proposed Rulemaking and Policy Statement on Bank Mergers
The Office of the Comptroller of the Currency (OCC) today requested comment on a proposal to update its rules for business combinations involving national banks and federal savings associations. The proposal also includes a policy statement to clarify the OCC’s review of applications under the Bank Merger Act (BMA).
Issue Date: 1/29/2024
Comments Due: 4/5/2024
FTC and DOJ Update Guidance That Reinforces Parties’ Preservation Obligations for Collaboration Tools and Ephemeral Messaging
The Federal Trade Commission and Justice Department today announced that both agencies are updating language in their standard preservation letters and specifications for all second requests, voluntary access letters, and compulsory legal process, including grand jury subpoenas, to address the increased use of collaboration tools and ephemeral messaging platforms in the modern workplace. These updates reinforce longstanding obligations requiring companies to preserve materials during the pendency of government investigations and litigation.
Issue Date: 1/26/2024
Federal Reserve Board announces it will extend the comment period on its interchange fee proposal until May 12, 2024 and published additional related data
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.
Issue Date: 1/22/2024
Comments Due: 5/12/2024
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.
Issue Date: 1/24/2024
Comments Due: 3/24/2024
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.
Issue Date: 1/17/2024
Comments Due: 4/1/2024
CFPB Addresses Inaccurate Background Check Reports and Sloppy Credit File Sharing Practices
Today, the Consumer Financial Protection Bureau (CFPB) issued guidance to consumer reporting companies to address inaccurate background check reports, as well as sloppy credit file sharing practices. The two advisory opinions seek to ensure that the consumer reporting system produces accurate and reliable information and does not keep people from accessing their personal data. First, an advisory opinion on background check reports highlights that those reports must be complete, accurate, and free of information that is duplicative, outdated, expunged, sealed, or otherwise legally restricted from public access. Second, an advisory opinion on file disclosure highlights that people are entitled to receive all information contained in their consumer file at the time they request it, along with the source or sources of the information contained within, including both the original and any intermediary or vendor source.
Issue Date: 1/11/2024
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.”
Issue Date: 1/9/2024
Comments Due: 02/13/2024
U.S. Beneficial Ownership Information Registry Now Accepting Reports
The U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) began accepting beneficial ownership information reports. The bipartisan Corporate Transparency Act, enacted in 2021 to curb illicit finance, requires many companies doing business in the United States to report information about the individuals who ultimately own or control them. Filing is simple, secure, and free of charge. Companies that are required to comply (“reporting companies”) must file their initial reports by the following deadlines:
–Existing companies: Reporting companies created or registered to do business in the United States before January 1, 2024 must file by January 1, 2025.
–Newly created or registered companies: Reporting companies created or registered to do business in the United States in 2024 have 90 calendar days to file after receiving actual or public notice that their company’s creation or registration is effective.
Issue Date: 1/1/2024
Effective Date: 01/1/2024
Extension of the Revised Statement Regarding Status of Certain Investment Funds and Their Portfolio Investments for Purposes of Regulation O and Reporting Requirements
The Board of Governors of the Federal Reserve Board (FRB), the Federal Deposit Insurance Corporation (FDIC), and the Office of the Comptroller of the Currency (OCC) (collectively, the “federal banking agencies”) are issuing the attached Interagency Statement, concerning Regulation O, to extend the expiration of certain no-action position previously provided in an interagency statement accompanying FIL 55-2022, dated December 22, 2022. Certain banking firms have raised concerns about the application of Regulation O to companies that sponsor, manage, or advise investment funds and institutional accounts that invest in voting securities of banking firms (such investment vehicles, collectively “funds,” and, together with the company that sponsors, manages, or advises them, “fund complexes”). Over the past few years, fund complexes have acquired, or have approached acquiring, more than 10 percent of a class of voting securities of a wide range of public companies, including banks and non-bank companies. Upon acquiring more than 10 percent of a class of voting securities of a banking firm, a fund complex would be a “principal shareholder” of the bank for purposes of Regulation O (a “principal shareholder fund complex”). Likewise, under Regulation O, any company in which a principal shareholder fund complex owns more than 10 percent of a class of voting securities could, in some instances, be presumed to be a “related interest” of the fund complex (“fund complex-controlled portfolio company”). The federal banking agencies would not take action against banks or principal shareholder fund complexes with respect to extensions of credit by the banks to fund complexcontrolled portfolio companies that otherwise would violate Regulation O, provided the fund complexes and banks satisfy the foregoing criteria. The no-action position provided herein covers extensions of credit to fund complex-controlled portfolio companies only, and does not extend to any extension of credit to principal shareholder fund complexes.
Issue Date: 12/15/2023
Effective Date: 01/1/2025
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.
Issue Date: 12/4/2023
Corporate Governance Policy and Policy Consideration Update
The Corporate Governance Policy Template and related Policy Consideration have been updated. They will be available to Policy Manager clients by Friday, December 8th. Changes were made response to the Federal Reserve’s Press Release entitled “Federal Reserve Board Finalizes a Rule Establishing Capital Requirements for Insurers Supervised by the Board” dated 10/06/23 which 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.
Issue Date: 12/4/2023
Artificial Intelligence Policy and Policy Consideration Update
The Artificial Intelligence Policy Template and related Policy Consideration have been updated. They will be available to Policy Manager clients by Friday, December 8th. Updates were made to incorporate best practices communicated through the NIST AI Risk Management Framework, and the AI Executive Order 14074, released on October 30, 2023. The policy template was updated to include accountability, and responsibilities for the development of AI technologies, and as well as to incorporating adequate third-party risk management considerations for using a vendor to offer AI services.
Issue Date: 12/4/2023
BSA Comprehensive Policy and Policy Consideration Update
The Comprehensive BSA 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 incorporate to address FinCEN’s counterterrorism priorities which included human trafficking, cryptocurrency, cybersecurity, digital currency, and other topics.
Issue Date: 12/4/2023
FinCEN Extends Deadline for Companies Created or Registered in 2024 to File Beneficial Ownership Information Reports
The Financial Crimes Enforcement Network (FinCEN) issued a final rule today that extends the deadline for certain reporting companies to file their initial beneficial ownership information (BOI) reports with FinCEN. Reporting companies created or registered in 2024 will have 90 calendar days from the date of receiving actual or public notice of their creation or registration becoming effective to file their initial reports. FinCEN will not accept BOI reports from reporting companies until January 1, 2024—no reports should be submitted to FinCEN before that date.
Issue Date: 11/29/2023
Effective Date: 01/1/2024
NCUA Reinstates Civil Money Penalties for Late Call Report Filing
“The program was suspended after the December 2019 cycle due to the COVID-19 pandemic,” NCUA Chairman Todd M. Harper said. “It is now time to reinstate the program to ensure we provide credit union members, the financial services stakeholders, other regulators, and the public with the most accurate and up-to-date quarterly Call Report data on a timely basis.”
Issue Date: 11/28/2023
Effective Date: 01/1/2024
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.
Issue Date: 11/17/2023
Effective Date: 01/2/2024
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.
Issue Date: 11/16/2023
Effective Date: 11/16/2024
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.
Issue Date: 11/22/2023
Comments Due: 01/16/2024
The updated Guidance for Nonbank Financial Company Determinations (Nonbank Designations Guidance) sets forth the Council’s procedures for considering whether to designate a nonbank financial company for Federal Reserve supervision and prudential standards under section 113 of the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank Act). The Nonbank Designations Guidance provides a transparent process and significant opportunities for engagement with both a nonbank financial company under review and its existing regulators.
Issue Date: 11/03/2023
Effective Date: 01/05/2024
CFPB Issues New Report on State Community Reinvestment Laws
Today, the Consumer Financial Protection Bureau (CFPB) published a new analysis on state Community Reinvestment Act laws, highlighting how states ensure financial institutions’ lending, services, and investment activities meet the credit needs of their communities. The report examined the laws of seven states (Connecticut, Illinois, Massachusetts, New York, Rhode Island, Washington, West Virginia) and the District of Columbia, and found that many of those states adopted laws similar to the federal Community Reinvestment Act in decades following the 1977 passage of the landmark federal anti-redlining law.
Issue Date: 11/02/2023
The Federal Reserve’s Press Release entitled “Federal Reserve Board Finalizes a Rule Establishing Capital Requirements for Insurers Supervised by the Board” dated 10/06/23 that 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.
Issue Date: 11/02/2023
Effective Date: 01/01/2024
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.
Issue Date: 11/02/2023
Effective Date: 09/01/2024
The Federal Housing Administration (FHA) today announced the publication of updated appraisal requirements for the valuation of manufactured homes certified under Fannie Mae’s MH AdvantageTM and Freddie Mac’s CHOICEHome® programs. The updates align FHA appraisal requirements with those of other industry participants and will improve the valuation of these homes for borrowers seeking FHA-insured mortgages.
Issue Date: 11/02/2023
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.
Issue Date: 10/26/2023
Effective Date: 12/26/2023
The Office of the Comptroller of the Currency (OCC), the Board of Governors of the Federal Reserve System, and the Federal Deposit Insurance Corporation (collectively, the agencies) today released a final rule to strengthen and modernize their regulations implementing the Community Reinvestment Act (CRA). The final rule revises the CRA regulations to better achieve the CRA’s core purpose of encouraging banks to help meet the credit needs of their local communities. It also adapts to changes in the banking industry, including the expanded role of mobile and online banking; provides greater clarity and consistency in the application of CRA regulations; tailors performance standards, data collection, and reporting requirements to account for differences in bank size, business model, and local conditions; promotes transparency and public engagement; confirms that CRA and fair lending responsibilities are mutually reinforcing; and promotes a consistent regulatory approach that applies to banks regulated by all three agencies. The final rule takes effect on April 1, 2024, with staggered compliance dates of January 1, 2026, and January 1, 2027.
Issue Date: 10/24/2023
Effective Date: 04/01/2024
The principles are intended to support efforts by the largest financial institutions to focus on key aspects of climate-related financial risk management. General climate-related financial risk management principles are provided with respect to a financial institution’s governance; policies, procedures, and limits; strategic planning; risk management; data, risk measurement, and reporting; and scenario analysis. Additionally, the principles describe how climate-related financial risks can be addressed in the management of traditional risk areas, including credit, market, liquidity, operational, and legal risks.
Issue Date: 10/24/2023
Agencies Monitored:
- CFPB (Consumer Financial Protection Bureau)
- FDIC (The Federal Deposit Insurance Corporation)
- IRS (Internal Revenue Service)
- OCC (The Office of the Comptroller of the Currency)
- Federal Reserve, NCUA (The National Credit Union Administration)
- FinCEN (Financial Crimes Enforcement Network)
- HUD (The Department of Housing and Urban Development)
Additional Resources:
Quickly find relevant industry websites including key regulations and regulatory bodies, audit/examination guidelines, state agencies and more.