There have been noteworthy regulatory and compliance updates for banks and credit unions throughout 2024. Below are the details on these changes and how they may impact you and your institution.
AUGUST 2024
Filing Instructions Guide for Small Business Lending Data Collected in 2025
The 2025 filing instructions guide is a set of resources to help you file small business lending data with the Consumer Financial Protection Bureau (CFPB) in 2026 covering the period from July 18, 2025 to December 31, 2025. These resources are briefly described in this section and are further detailed throughout this web page in individual sections.
These resources may be useful for employees in a variety of roles, for example:
- Staff who collect, prepare, and submit data
- Technology support staff
- Compliance officers
The CFPB has also updated its additional resources.
Why Is This Important to Me?
- This guide is meant to provide resources to help institutions required to file small business lending data with the CFPB in 2026, covering the period from 7/18/25 – 12/31/25, based on the Section 1071 rule.
FDIC Updates Q&As Related to Part 328 Final Rule
The Federal Deposit Insurance Corporation (FDIC) recently published a series of Questions and Answers (Q&As) related to the final rule governing FDIC Official Signs and Advertising Requirements, False Advertising, Misrepresentation of Insured Status, and Misuse of the FDIC Name or Logo (part 328). The Q&As are a collection of the most frequently asked questions that the FDIC has received to date from stakeholders, including banks, trade associations, technology companies, vendors, and other entities. The Q&As provide clarifying information on the final rule to support stakeholders in the implementation of part 328.
Direct link to the Q&As can be found here.
Why Is This Important to Me?
- The rule went into effect on 4/1/24, requiring full compliance by 1/1/25.
OCC Releases Annual Update to Bank Accounting Advisory Service (BAAS)
The Office of the Chief Accountant (OCA) is pleased to present the August 2024 edition of the Bank Accounting Advisory Series (BAAS). The BAAS expresses the OCA's interpretations of accounting topics relevant to national banks and federal savings associations (collectively, banks or institutions, unless otherwise specified). We hope that you find this publication useful and that it continues to be a practical resource for banks and examiners.
Why Is This Important to Me?
- This publication assists institutions with best practices and recommendations of generally accepted accounting principles and regulatory guidance based on facts presented.
JULY 2024
Agencies Request Comment on Anti-Money Laundering/Countering the Financing of Terrorism Proposed Rule
Four federal financial institution regulatory agencies today requested comment on a proposal to update their requirements for supervised institutions to establish, implement, and maintain effective, risk-based, and reasonably designed anti-money laundering and countering the financing of terrorism (AML/CFT) programs. The amendments are intended to align with changes concurrently proposed by the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN), most of which result from the Anti-Money Laundering Act of 2020 (AML Act).
The proposed amendments would require supervised institutions to identify, evaluate, and document the regulated institution’s money laundering, terrorist financing, and other illicit finance activity risks, as well as consider, as appropriate, FinCEN’s published national AML/CFT priorities. Additionally, and consistent with the AML Act, the proposal would mandate that the duty to establish, maintain, and enforce the AML/CFT program remain the responsibility of, and be performed by, persons in the United States who are accessible to, and subject to the oversight and supervision by, the relevant agency. The proposal also supports institutions’ consideration of innovative approaches to meet compliance obligations.
Comments on the proposal are due 60 days after the date of publication in the Federal Register.
Why Is This Important to Me?
- Just an FYI at this time, but there may be updates to AML/CFT requirements in the near future.
Spring 2024 Unified Agenda of Regulatory and Deregulatory Actions Released
The agenda includes four proposed rule actions around FCRA, mortgage servicing, the Financial Data Transparency Act, and consumer financial product contracts under Regulation AA.
Why Is This Important to Me?
- There will likely be proposed revisions to those above-mentioned regulations in the latter half of the year.
Agencies Release List of Distressed or Underserved Nonmetropolitan Middle-Income Geographies
Federal bank regulatory agencies today released the 2024 list of distressed or underserved nonmetropolitan middle-income geographies where certain bank activities are eligible for Community Reinvestment Act (CRA) credit.
Why Is This Important to Me?
- Revitalization or stabilization activities in these geographies are eligible to receive CRA consideration under the community development definition for 12 months after publication of the current list.
JUNE 2024
OCC Reports on Key Federal Banking System Risks
The OCC highlighted credit, market, operational, and compliance risks as key themes within the report.
Why Is This Important to Me?
- Share this information with your colleagues to ensure you have training to adequately address these risk areas.
Fed Releases the Federal Open Market Committee Statement
Recent indicators suggest that economic activity has continued to expand at a solid pace. Job gains have remained strong, and the unemployment rate has remained low. Inflation has eased over the past year but remains elevated. In recent months, there has been modest further progress toward the Committee's 2 percent inflation objective.
Why Is This Important to Me?
- Use this information to make training determinations in the near future.
OCC Revises Retail NDIP Handbook
This booklet discusses risks and risk management practices associated with the recommendation or sale of nondeposit investment products to retail customers. This booklet also provides examiners with a framework for evaluating a bank’s retail nondeposit investment product program.
Why Is This Important to Me?
- The revised booklet provides clarity around risk management practices and guidance for examiners.
FinCEN Updates Beneficial Ownership FAQs
FinCEN has updated the Beneficial Ownership Information FAQs to include more information around exemptions, beneficial owners, and reporting requirements.
Why Is this Important to Me?
OnCourse Learning has multiple beneficial ownership trainings, from our online self-paced Beneficial Ownership course to our multiple Beneficial Ownership webinars.
MAY 2024
OCC’s Community Bank Director and Senior Management Workshops
The OCC’s workshops deliver important content led by some of the OCC’s most experienced and qualified professionals. These sessions are designed to meet the needs of new directors, experienced directors, and senior management looking to review the fundamentals or get critical updates.
Why Is This Important to Me?
- Share this information with your Board of Directors.
CFPB Extends Compliance Deadlines for 1071
The CFPB is extending compliance deadlines for the small business lending rule. After the CFPB issued this rule on March 30, 2023, some lenders filed challenges against it in federal court in Texas. On July 31, 2023, that court stayed the rule for certain lenders pending the Supreme Court’s decision in CFPB v. CFSA; on October 26, it extended that stay to all lenders covered by the rule. In the event of a reversal in CFSA, the Texas court ordered the CFPB to extend the rule’s compliance deadlines to compensate for the period stayed.
The CFPB now plans to issue an interim final rule to extend compliance deadlines:
- For Tier 1 institutions (highest volume lenders), the original compliance date of October 1, 2024, will be extended to July 18, 2024, and the first filing deadline will be June 1, 2026.
- For Tier 2 institutions (moderate volume lenders), the April 1, 2025, compliance date will be extended to January 16, 2026, with a first filing deadline on June 1, 2027.
- For Tier 3 institutions (smallest volume lenders), the January 1, 2026, compliance date will be extended to October 18, 2026, with a first filing deadline on June 1, 2027.
Why Is This Important to Me?
- Now that CFPB vs. CFSA has been settled, we will likely see an increase in 1071 training events around the new deadline extensions.
Reg CC Funds Availability Inflation Adjustments
The Board & the CFPB are amending Regulation CC, which implements the Expedited Funds Availability Act (EFA Act) and the Check Clearing for the 21st Century Act (Check 21 Act), to fulfill a statutory requirement in the EFA Act to adjust the dollar amounts under the EFA Act for inflation, effective July 1, 2025. The new amounts are as follows:
- The "next day" minimum availability amount will increase from $225 to $275
- The cash withdrawal amount in § 229.12(d) will increase from $450 to $550
- The new account, large deposit threshold, and repeatedly overdrawn thresholds in § 229.13 will increase from $5,525 to $6,725
- The civil liability minimum and maximum for individuals actions in § 229.21(a)(2)(i) will increase from $100 and $1,100 to $125 and $1,350
- The civil liability maximum for class action in § 229.21(a)(2)(ii)(B) will increase from $552,500 to $672,950 or 1 percent of the bank's worth, whichever is less.
Why Is This Important to Me?
- All of OnCourse Learning’s applicable courseware will be updated to reflect the new amounts beginning in 2025.
Agencies Issue Guide to Assist Community Banks to Develop and Implement Third-Party Risk Management Practices
Federal bank regulatory agencies today released a guide to support community banks in managing risks presented by third-party relationships. Community banks engage with third parties to help compete in and respond to an evolving financial services landscape. Third-party relationships present varied risks that community banks are expected to appropriately identify, assess, monitor, and control to ensure that their activities are performed in a safe and sound manner and in compliance with applicable laws and regulations. These laws and regulations include, but are not limited to, those designed to protect consumers and those addressing financial crimes. The guide offers potential considerations, resources, and examples through each stage of the third-party relationship and may be a helpful resource for community banks. While the guide illustrates the principles discussed in the third-party risk management guidance issued by the agencies in June 2023, it is not a substitute for that guidance.
Why Is this Important to Me?
- OnCourse Learning has multiple vendor management trainings, from our online self-paced The Importance of Third-Party Vendor Management course to our multiple vendor management
APRIL 2024
Biden-Harris Administration Finalizes Rule to Increase Compensation Thresholds for Overtime Eligibility
The Biden-Harris administration today announced a final rule that expands overtime protections for millions of the nation’s lower-paid salaried workers by increasing the salary thresholds required to exempt a salaried bona fide executive, administrative or professional employee from federal overtime pay requirements.
Effective July 1, 2024, the salary threshold will increase to the equivalent of an annual salary of $43,888 and increase to $58,656 on Jan. 1, 2025. The July 1 increase updates the present annual salary threshold of $35,568 based on the methodology used by the prior administration in the 2019 overtime rule update. On Jan. 1, 2025, the rule’s new methodology takes effect, resulting in the additional increase. In addition, the rule will adjust the threshold for highly compensated employees. Starting July 1, 2027, salary thresholds will update every three years, by applying up-to-date wage data to determine new salary levels.
Why Is This Important to Me?
- The first threshold increase begins soon – July 1, increasing the salary requirement to $43,888. This is a dramatic change to the current $35,568 requirement. OnCourse Learning has an upcoming webinar to provide the range of compliance options and considerations to weigh when evaluating these options. New FLSA Overtime Exemption Regulations - Required Action Items Prior to July 1.
FTC Announces Rule Banning Noncompetes
The Federal Trade Commission (FTC) issued a final rule to promote competition by banning noncompetes nationwide, protecting the fundamental freedom of workers to change jobs, increasing innovation, and fostering new business formation.
Why Is This Important to Me?
- The final rule banning noncompetes will likely lead to new business formation, result in higher earnings for workers, and is expected to lower healthcare costs over the next decade. Additionally, the final rule is expected to help drive innovation.
FinCEN Reminds Financial Institutions to Remain Vigilant to Environmental Crimes
FinCEN issued a reminder to financial institutions on Earth Day (04/22) to remain vigilant in identifying and reporting suspicious activity related to environmental crimes. Environmental crimes frequently involve transnational criminal activity related to several of FinCEN’s Anti-Money Laundering and Countering the Financing of Terrorism (AML/CFT) National Priorities, including corruption, fraud, human trafficking, and drug trafficking.
Why Is This Important to Me?
- OnCourse Learning has many different online self-paced courses and webinars that cover topics such as anti-money laundering, anti-terrorism, fraud, bribery, and human trafficking to ensure our clients are educated in these topics.
FinCEN Updates Beneficial Ownership FAQs
FinCEN has updated its Beneficial Ownership FAQs to include new questions and updated information about reporting companies, beneficial ownership through trusts, and access to beneficial ownership information.
Why Is this Important to Me?
- There have been some updates to Beneficial Ownership for 2024, specifically a final rule implementing the access and safeguard provisions of the Corporate Transparency Act (CTA). OnCourse Learning has multiple online self-paced courses, as well as a webinar detailing this updated rule.
FDIC Requests Comments on Proposed State 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.
Why Is This Important to Me?
- Mergers & acquisitions are expected to be a hot topic throughout 2024. The FDIC encourages comments from all interested parties within 60 days of publication in the Federal Register.
FTC Amends Telemarketing Sales Rule
The Federal Trade Commission (“FTC” or “Commission”) adopts amendments to the Telemarketing Sales Rule (“TSR”) that, among other things, require telemarketers and sellers to maintain additional records of their telemarketing transactions, prohibit material misrepresentations and false or misleading statements in business to business (“B2B”) telemarketing calls, and add a new definition for the term “previous donor.” These amendments are necessary to address technological advances and to continue protecting consumers, including small businesses, from deceptive or abusive telemarketing practices.
Why Is This Important to Me?
- The amendments are effective 05/16/2024. However, compliance with 16 CFR 310.5(a)(2) is not required until 10/15/2024. OnCourse Learning has just released an updated Telemarketing Consumer Fraud and Abuse Prevention Act – E3 course in April 2024.
MARCH 2024
FDIC Seeks Public Comment on Proposed Revisions to its Statement of Policy on Bank Merger Transactions
The Federal Deposit Insurance Corporation (FDIC) Board of Directors today approved a Federal Register notice seeking public comment on proposed revisions to the agency’s Statement of Policy (revised SOP) on Bank Merger Transactions.
The FDIC encourages comments from all interested parties within 60 days of publication in the Federal Register.
Why Is This Important to Me?
- Comments from all parties need to be received within 60 days of publication in the Federal Register.
Agencies Extend Applicability Date of Certain Provisions of Community Reinvestment Act Final Rule
Federal bank regulatory agencies today jointly issued an interim final rule that extends the applicability date of certain provisions in their Community Reinvestment Act (CRA) final rule issued in October 2023. The agencies also requested comment on the extension.
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.
Why Is this Important to Me?
- Institutions will not have to make changes to their assessment areas & public file provisions until January 1, 2026. Originally, institutions were required to make changes as of April 1, 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.
Why Is This Important to Me?
- All OnCourse Learning Telemarketing Consumer Fraud courses will be updated to reflect these new protections to businesses & the updated recordkeeping requirements.
January 2024
CFPB Proposes Rule to Stop New Junk Fees on Bank Accounts
The CFPB proposed 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 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.
Share the below upcoming webinar on 01/30/2024 with customers who may have questions:
Deposit Operations - First Quarter Update
Federal Reserve Releases Video on New CRA Rule and Objectives
This video released on January 10th provides an overview of the new CRA rule and its objectives. The video also addresses assessment areas, community development, evaluation framework, performance tests, ratings, data collection and reporting, and applicability dates.
Share the below OnDemand webinar from 01/10/2024 with customers who may have questions:
FinCEN Issues Analysis of Identity-Related Suspicious Activity
FinCEN issues a Financial Trend Analysis on information linked to identity-related suspicious activity in BSA reports filed in 2021. FinCEN’s analysis found that approximately 1.6 million reports (42% of the reports filed that year) related to identity—indicating $212 billion in suspicious activity.
This report explores identity-related processes were exploited in processing transactions as well as opening and accessing accounts. Of over 14 typologies regularly indicated in BSA reports, the most frequently reported were fraud, false records, identity theft, third-party money laundering, and circumvention of verification standards. These accounted for 88% of identity-related BSA reports and 74% of the total identity-related suspicious activity amount reported during 2021.
Share the below OnDemand webinar from 01/16/2024 with customers who may have questions:
About the Author
Jeff Kelly
General Manager at OnCourse Learning
As General Manager at OnCourse Learning, Jeff leads the product management and learning development teams, along with solutions architecture and compliance functions. Jeff has worked in the financial services industry for 20 years and keeps up to date on financial industry changes and updates. Jeff obtained his Bachelor’s Degree in Marketing from the University of Wisconsin – Whitewater and his MBA from the University of Wisconsin – Milwaukee. He also served in the U.S. Marine Corps as a non-commissioned officer. His focus is building strong collaborative teams with passion for delivering excellence in outcomes for customers and employees.
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