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The CFPB’s Office of Financial Protection for Older Americans has issued a new report on combating elder abuse. Titled “Suspicious Activity Reports on Elder Financial Exploitation: Issues and Trends,” the report draws on a non-public data derived from Suspicious Activity Reports (SARs) filed with federal regulators from 2013 to 2017.… Continue Reading

The Federal Banking Agencies (“FBAs”) — collectively the Office of the Comptroller of the Currency (“OCC”); the Board of Governors of the Federal Reserve System (“Federal Reserve”); the Federal Deposit Insurance Corporation (“FDIC”); and the National Credit Union Administration (“NCUA”) — just issued with the concurrence of FinCEN an Order granting an exemption from the requirements of the customer identification program (“CIP”) rules imposed by the Bank Secrecy Act (“BSA”) under 31 U.S.C.… Continue Reading

As we reported in an earlier posting, it has taken considerable effort to locate the memoranda of understanding (MOUs) that the CFPB has put in place with various other federal agencies. More of those MOUs recently surfaced through, we believe, a Freedom of Information Act (FOIA) request. One of the newly uncovered MOUs is between CFPB and FinCEN and gives the CFPB direct electronic access to Bank Secrecy Act information collected in FinCEN’s Currency and Banking Retrieval System.… Continue Reading