March 2017 A Regulatory & Legislative Advisory for Compliance Professionals
Inside . . .
2 ABA to FCC:
Ability to Contact
Bank Secrecy Act
3 FinCEN Renews
GTOs on High-End
3 FATF Plenary
4 FTC Annual
5 Trump Orders Reg
Reform Efforts at
5 OCC Issues Draft
Licensing Manual for
ABA'S BANK CHIEF COMPLIANCE OFFICER SURVEY
OPEN UNTIL MARCH 24
The ABA Center for Regulatory Compliance is asking ABA member banks and
savings institutions to participate by March 24 in the 2017 ABA Bank Compliance
Officer Survey. The survey is designed to take a snapshot of the compliance function
at ABA member institutions, and the institution’s chief compliance officer or designee
should complete it. This survey has been conducted biennially since 2003.
Compliance officers can print out the survey to review the questions and then make
responses online once they have gathered the needed information. All responses will
be kept confidential.
Survey participants will be entered in a random drawing to win a complimentary
registration for any 2017 ABA briefing. Each institution’s compliance officer or another
official was sent an electronic invitation on February 23. If your institution did not
receive that invitation, please register for the survey here. For more information,
contact ABA's Rick Freer.
CFPB DELAYS PREPAID RULE EFFECTIVE DATE
The Consumer Financial Protection Bureau on March 9 proposed extending the
effective date of its final rule on covered prepaid accounts. Originally scheduled to
take effect on October 1, the proposal would move the effective date to April 1, 2018.
Comments on the proposal are due by April 5.
The agency said that "through our efforts to support industry implementation, we have
learned that some industry participants believe they will have difficulty complying with
certain provisions of the rule by the current October 1, 2017 effective date." The CFPB
also invited comments from the public on how implementation challenges may affect
consumers." If we determine that any substantive changes to the prepaid accounts
rule are necessary and appropriate, we will issue a separate proposal and provide the
public an opportunity to comment on those changes before finalizing, it said. Read
CFPB Publishes Guide to Prepaid Rule Disclosures
Separately, the CFPB has published a guide on the short-form disclosures required by
its final rule on prepaid accounts. The guide provides basic instructions on how to
prepare the disclosures for prepaid accounts other than government benefit accounts
or payroll account cards. The final rule amends Regulation E to encompass prepaid
cards as well as Regulation Z to cover prepaid products with credit-style elements.