Welcome to the Compliance Cohort. We are a group of compliance professionals working to make compliance easier. Our goal is to take complex compliance concepts and put them in simple terms that apply to the real world. We are glad you have found us and look forward to collaborating in the future.
If you haven't done so already, make sure you sign up for our free membership where you get access to many member-only videos, articles, and other resources.
All by Adam Witmer
In this Compliance Clip (video), Adam discusses the nuances of adverse action notices in the context of declined counteroffers for commercial loans. He explains the regulatory framework under Regulation B and the implications for lenders when an applicant withdraws their application after a counteroffer is declined.
Our Regulation E Bootcamp is currently on sale in our store. Our Regulation E Bootcamp is designed to review the requirements of the Electronic Fund Transfer Act (EFTA), as implemented by Regulation E, including a deep dive into the liability and error resolution rules. The goal of this program is to cover the main elements of Regulation E that would apply to your organization while spending extra time on the areas that have the greatest risk for non-compliance. You can register for this program at www.compliancecohort.com/regulation-e-bootcamp.
Our 2024 FDIC Official Signs & Advertising Final Rule is currently on sale in our store. Our FDIC Advertising Rules class is designed to equip financial professionals with an understanding of the final rule of the new FDIC advertising and how it will affect their banks. The program includes an introduction and background of the FDIC’s official signs and advertising of membership rules, a review of Subpart A of the FDIC final rule in detail, and the elements of Subpart B that changed in the final rule. This new FDIC rule is going to be extremely important for banks to pay attention to as the rule saw several significant updates for current technology and electronic delivery channels. To learn more and register for our 2024 FDIC Official Signs & Advertising Final Rule, go to www.compliancecohort.com/2024-fdic-final-rule.
In this Compliance Clip (video), Adam discusses the critical concept of "permissible purpose" when obtaining credit reports under the Fair Credit Reporting Act (FCRA). Understanding these guidelines is essential for lenders and creditors to avoid significant legal violations and breaches of privacy.
In case you missed our announcement earlier this week, we are giving away one enrollment to our upcoming Regulation E Bootcamp. Our Regulation E Bootcamp is designed to provide attendees with an overview of the requirements of Regulation E or the Electronic Fund Transfer Act (EFTA), including a deep dive into the liability and error resolution rules of Regulation E. You can learn more about this program at www.compliancecohort.com/regulation-e-bootcamp. To enter for a chance to win one enrollment in our Regulation E Bootcamp, just complete the short entry form at www.compliancecohort.com/entry. All entries must be received by 3/10/25 at 2:59 PM Eastern and the full official contest rules can be found at www.compliancecohort.com/contest.
On 3/5/25, the CFPB published in the Federal Register a proposed rule to extend the comment period from the 12/13/24 notice of proposed ruemaking requesting comment on the CFPB’s proposal to amend Regulation V.
On 3/3/25, the FDIC announced that it was postponing the compliance date from May 1, 2025 to March 1, 2026 for the requirements under 12 CFR 328.5 related to the display of the FDIC official digital sign on an insured depository institution’s (IDI’s) digital channels, as well as analogous requirements related to IDI’s automated teller machines (ATMs) and like devices under 12 CFR 328.4.
On 3/3/25, NCUA Chairman, Kyle S. Haptman, announced that the NCUA “will no longer publish overdraft and non-sufficient fund fee income for individual credit unions.” The NCUA will, however, continue to collect the data during supervisory examinations.
On 3/3/25, the FDIC announced that it was withdrawing three proposed rules relating to brokered deposits, corporate governance, and the Change in Bank Control Act (CBCA). The FDIC also announced a withdraw of the authority previously approved by the FDIC Board of Directors to publish a proposed rule on incentive-based compensation arrangements.
On 2/27/25, FinCEN announced that it will not impose fines, penalties, or any other enforcement actions against companies that fail to file or update beneficial ownership information (BOI) reports under the Corporate Transparency Act by the current deadlines. In a news release, FinCEN stated that “no fines or penalties will be issued, and no enforcement actions will be taken, until a forthcoming interim final rule becomes effective and the new relevant due dates in the interim final rule have passed.”
