Regulatory Compliance Updates for Banks & Credit Unions – September 2022 Recap

There were two noteworthy regulatory and compliance updates for banks and credit unions in September of 2022. Below are the details on these changes and how they affect you and your institution.

July Regulatory Compliance Updates for Banks and Credit Unions

CFPB: Mortgage Refinances and Forbearances

The CFPB announced on September 22, 2022, it is seeking comment from the public about ways to facilitate mortgage refinances for consumers who would benefit from refinancing, especially consumers with smaller loan balances; and, ways to reduce risks for consumers who experience disruptions in their financial situation that could interfere with their ability to remain current on their mortgage payments.

Why Is This Important to Me?

Comments are due by November 28, 2022.

FinCEN: Final Beneficial Ownership Reporting Rule Issued

On September 29, 2022, FinCEN announced it has issued a final rule establishing a beneficial ownership information reporting requirement, as required under the Corporate Transparency Act (CTA). The rule will require most corporations, limited liability companies, and other entities created in or registered to do business in the U.S. to report information about their beneficial owners, the persons who ultimately own or control the company, to FinCEN.

Reporting companies created or registered before January 1, 2024, will have one year (until January 1, 2025) to file their initial reports, while reporting companies created or registered after January 1, 2024, will have 30 days after creation or registration to file their initial reports. Once the initial report has been filed, both existing and new reporting companies will have to file updates within 30 days of a change in their beneficial ownership information.

The reporting rule is one of three rulemakings planned to implement the CTA. FinCEN will engage in additional rulemakings to: (1) establish rules for who may access beneficial ownership information, for what purposes, and what safeguards will be required to ensure that the information is secured and protected; and (2) revise FinCEN’s customer due diligence rule. In addition, FinCEN continues to develop the infrastructure to administer these requirements, including the information technology system that will be used to store beneficial ownership information in accordance with the strict security and confidentiality requirements of the CTA.

Banks should note that the rule issued yesterday does not reduce or change in any way the customer due diligence rule that requires banks to obtain certifications of beneficial ownership from their legal entity customers. Any change in that requirement will take place after yesterday’s rule has become effective, and the system that will store the beneficial ownership data has been designed and implemented and proven to be effective.

Why Is This Important to Me?

The effective date is January 1, 2024.

Rachel Davis - Product Manager at OCL

About the Author

Rachel Davis

Product Manager at OnCourse Learning

Rachel Davis is the Product Manager of GRC and professional education for banks, credit unions, and non-bank financial services at OnCourse Learning. Rachel has worked in the financial services industry for 12 years and keeps up to date on financial industry hot topics. Rachel received her Bachelor of Arts in English Literature from Saint Louis University.

Rachel Davis - Product Manager at OCL

About the Author

Rachel Davis

Product Manager at OnCourse Learning

Rachel Davis is the Product Manager of GRC and professional education for banks, credit unions, and non-bank financial services at OnCourse Learning. Rachel has worked in the financial services industry for 12 years and keeps up to date on financial industry hot topics. Rachel received her Bachelor of Arts in English Literature from Saint Louis University.

By |2022-10-04T10:00:39-06:00October 4th, 2022|Bank, Credit Union, Financial Services|Comments Off on Regulatory Compliance Updates for Banks & Credit Unions – September 2022 Recap