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FinCEN report: SARs help prevent elder financial exploitation
On December 4, FinCEN announced the release of a Financial Trend Analysis titled, “Elders Face Increased Financial Threat from Domestic and Foreign Actors.” In compiling the report, FinCEN reviewed Bank Secrecy Act (BSA) elder financial exploitation suspicious activity reports (SARs) from 2013 to...
InfoBytesFDIC posts enforcement actions manual
On December 2, the FDIC announced the release of its full enforcement manual (manual). According to Financial Institution Letter (see FIL-76-2019 ), the manual, which was posted to the FDIC website, is meant to “support the work of field office, regional office, and Washington office staff involved...
InfoBytesOFAC announces settlement with company that allegedly processed payments for sanctioned entity
On November 25, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) announced a $466,912 civil settlement with a California-based technology company to resolve alleged violations of the Foreign Narcotics Kingpin Sanctions Regulations (FNKSR). According to OFAC, the company...
InfoBytesOFAC identifies Venezuelan oil tankers as blocked property
On December 3, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) announced additions to the Specially Designated Nationals List (SDN List) pursuant to Executive Order 13884, which blocks the property of the Venezuelan government. OFAC identified six tankers of Venezuela’s state...
InfoBytesBuckley Insights: Trends show DDoS attacks continue to increase
On November 19, Neustar released a report showing a 241 percent increase in Distributed Denial of Service (DDoS) attacks in 3Q 2019 versus 3Q 2018. Notably, a couple of new and emerging methods of DDoS attacks have emerged, including: DDoS reflection/amplification attacks take advantage of IP...
InfoBytesWisconsin to provide temporary authority for MLOs
On November 26, the Wisconsin governor signed SB 457 , which, among other things, includes provisions granting temporary authority for certain mortgage loan originators (MLOs) to originate loans in the state while their license applications are pending. Specifically, SB 457 provides that in order...
InfoBytesFSOC issues final guidance on nonbank designations; highlights key risks in annual report
On December 4, the Financial Stability Oversight Council (FSOC) issued final interpretive guidance to revise and update 2012 guidance concerning nonbank financial company designations. According to Treasury Secretary Steven T. Mnuchin, the guidance “enhances [FSOC’s] ability to identify, assess,...
InfoBytesSenate Democrats criticize OCC and FDIC fintech proposals
On November 21, six Democratic Senators wrote to OCC Comptroller Joseph Otting and FDIC Chairman Jelena Williams to strongly oppose recent proposed rules by the agencies (see OCC notice here and FDIC notice here ). As previously covered by a Buckley Special Alert , the OCC and FDIC proposed rules...
InfoBytesAppeals Court affirms enforceability of arbitration agreement
On November 27, the Superior Court of New Jersey, Appellate Division, affirmed an order requiring arbitration between a consumer and the buyer of the consumer’s debt (debt collector) in a lawsuit filed by the consumer claiming that the debt collector was not licensed to collect debts in New Jersey...
InfoBytesRegulators issue joint statement on using alternative data in underwriting
On December 3, the Federal Reserve, the CFPB, the FDIC, the NCUA, and the OCC (agencies) issued an Interagency Statement on alternative data use in credit underwriting, highlighting applicable consumer protection laws and noting risks and benefits. (See press release here ). According to the...
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