Oct 1
Oct 1 Treasury Cracks Down on Illicit Russian Virtual Currency Exchanges and Cybercrime Facilitator

On September 26, 2024, the U.S. Department of the Treasury announced that it is undertaking actions as part of a coordinated international effort to disrupt Russian cybercrime services. In line with this, FinCEN has issued an order that identifies PM2BTC as being of “primary money laundering concern” in connection with Russian illicit finance.

Sep 26
Sep 26 CFPB Issues Office of Servicemember Affairs 2023 Annual Report

Adam Witmer

Regulatory Update

On September 24, 2024, the CFPB issued the Office of Servicemember Affairs’ annual report for 2023 which covers the top financial concerns facing servicemembers, veterans, and military families, based on the complaints they submitted to the CFPB. The reports also identify emerging risks in consumer finance and provide an update on the CFPB’s efforts toward continuing to protect the military community from harmful financial products and practices.

Sep 25
Sep 25 HMDA FIG Updated for 2025

Adam Witmer

Regulatory Update, HMDA

On September 20, 2024, the CFPB released the HMDA Filing Instructions Guide (FIG) for data collected in 2025. As this guide is updated on an annual basis for the new year, there appears to be minimal changes in the newest version of the Guide.

Sep 23
Sep 23 CFPB Proposes Changes to Remittance Transfer Rule

Adam Witmer

Regulation E, Regulatory Update

On September 20, 2024, the CFPB issued a proposed rule with a narrow amendment to disclosure requirements for certain international money transfers, or remittances. The proposed change aims to ensure that consumers sending a remittance transfer have information about the types of inquiries that may be most efficient to direct to the CFPB and the State agency that licenses or charters their remittance transfer provider.

Sep 23
Sep 23 FinCEN Issued Beneficial Ownership Reporting Outreach and Education Toolkit

Adam Witmer

BSA, Regulatory Update

On September 19, 2024, FinCEN issued another resource to familiarize small business owners with beneficial ownership reporting requirements. The toolkit includes general background on the reporting requirements, as well as templates for newsletters, websites, and emails; sample social media posts and images; and information on how to contact FinCEN.

Sep 23
Sep 23 HUD Settlement with OceanFirst Bank for Lending Discrimination

Adam Witmer

Regulatory Update, Fair Lending

On September 18, 2024, the HUD announced the approval of a Conciliation Agreement with OceanFirst Bank for engaging in redlining by restricting access to credit and mortgage lending services in majority-Black, Hispanic, and Asian neighborhoods in the New Brunswick, New Jersey area. The HUD’s investigation was conducted alongside the DOJ after a referral from the OCC.

Sep 19
Sep 19 CFPB Publishes Buy Now, Pay Later Product FAQs

Adam Witmer

Regulatory Update

On September 18, 2024, the CFPN released a set of Questions and Answers for Buy Now, Pay Later products. The FAQs pertain to compliance with Regulation Z, which implements TILA, as related to Buy Now, Pay Later products.

Sep 19
Sep 19 CFPB Issues Guidance on Improper Overdraft Opt-In Practices

Adam Witmer

Regulatory Update

On September 17, 2024, the CFPB published guidance to help federal and state consumer protection enforcers stop banks from charging overdraft fees based on phantom opt-in agreements. According to CFPB Director Rohit Chopra, the Bureau has found instances where banks have no evidence that they obtained consent for overdrafts.

Sep 17
Sep 17 FinCEN Proposes Renewal of Monetary Instruments Recordkeeping Rule

Adam Witmer

BSA, Regulatory Update

On September 17, 2024, FinCEN issued a notice and request for comments on the proposed renewal, without change, of existing information collection requirements found in BSA regulations that require financial institutions to maintain records related to the issuance or sale of bank checks and drafts, cashier's checks, money orders, and traveler's checks when the issuance or sale involves the use of currency in an amount between $3,000 and $10,000, inclusive.

Sep 16
Sep 16 CFPB Sues Horizon Card Services and its CEO Robert Kane for Deceptive Credit Card Marketing

Adam Witmer

Regulatory Update, UDAAP

On September 13, 2024, the CFPB sued Horizon Card Services and its CEO Robert Kane for tricking consumers into signing up for its expensive membership credit card. The CFPB alleges Horizon and Kane attracted consumers to the membership program through deceptive marketing tactics.