Page 8 - July 18, 2024 Bulletin

aRTiCLeS

Americans Struggling with FinCEN Proposes New
Emergency Savings Requirements for Financial

High inflation and interest rates since the COVID-19 pandemic Institution AML/CFT Programs
have continued to make it difficult for people to feel comfortable The Financial Crimes Enforcement Network has proposed a new
with their level of emergency savings, according to Bankrate’s recent rule to require financial institutions to establish and maintain
2024 Annual Emergency Savings Report. “effective, risk-based and reasonably designed” anti-money

Nearly six in 10 (59%) U.S. adults are uncomfortable with their level laundering/countering the financing of terrorism programs with
of emergency savings, according to the Bankrate poll. Before 2022, certain minimum components, including a mandatory risk
the percentage had been rising, from 37% in 2018 to 44% in 2020, assessment process. The proposed rule also would require financial
48% in 2021 and 58% in 2022. This year, it hasn’t changed much institutions to review government-wide AML/CFT priorities and
from 57% in 2023. incorporate them “as appropriate” into risk-based programs, and
would make other changes to program requirements, a pillar of
Since 2014, the survey has annually polled more than 1,000 U.S.
adults about their level of debt and emergency savings. The most recent banks’ Bank Security Act/AML/CFT compliance.
data, polled in May 2024, also examined how much savings people Earlier, the Federal Reserve, OCC, FDIC and National Credit
would need to feel comfortable and if they have that much saved. Union Administration previewed a separate proposed rule that
would align each agency's BSA compliance program requirements
Common personal finance advice recommends keeping three
months of expenses in a savings account in case of a job loss or other with FinCEN’s proposed changes, which are being made to
emergency, and Bankrate’s data shows most people agree with that. implement provisions of the Anti-Money Laundering Act of 2020.
The vast majority (89%) of U.S. adults say they would need at least Among other things, FinCEN said the proposed rule seeks to
three months of expenses saved to feel comfortable. Despite that, avoid “one-size-fits-all approaches to customer risk that can lead to
only 44% of Americans have at least three months of expenses saved, financial institutions declining to provide financial services to entire
according to Bankrate. categories of customers.”
“More than ever, financial institutions are partnering with
Read more: https://www.bankrate.com/banking/savings/emergency- government to address a range of serious law enforcement and
savings-report/
national security issues with illicit financing implications, from
FHFA, CFPB Release Updated fentanyl trafficking to Russia’s illegal invasion of Ukraine,” Deputy
Secretary of the Treasury Wally Adeyemo said in a statement. “It
Mortgage Origination Data has been an important priority for Treasury to issue this proposed
rule that promotes a more effective and risk-based regulatory and
The Federal Housing Finance Agency and the CFPB released supervisory regime that directs financial institutions to focus their
updated loan-level data collected through the National Survey of AML/CFT programs on the highest priority threats.”
Mortgage Originations. The 2024 release includes – the first since
December 2022 – includes data on three new survey questions first Read more: https://www.federalregister.gov/
fielded in 2021. documents/2024/07/03/2024-14414/anti-money-laundering-and-
countering-the-financing-of-terrorism-programs
The latest survey release shows that 70% of respondents said they
were very satisfied with their property appraisal and 23% were View FinCEN’s fact sheet, visit: https://www.fincen.gov/sites/default/
somewhat satisfied, with just 6% not satisfied. Half of borrowers files/shared/Program-NPRM-FactSheet-508.pdf
surveyed expressed unwillingness to move from their primary
residence, with a quarter willing and able, 5% willing but unable and ABA, State Bankers Associations:

20% not sure. Congress, not Regulators, Should
The survey – which asks borrowers about their experiences obtaining Set FHLB Mission
a mortgage, perceptions of the mortgage market and future
expectations – is part of the agencies’ National Mortgage Database. A recent request for input on the Federal Home Loan Banks’ mission
The database was established in 2012, and the release added suggests that regulators are considering significant regulatory action
mortgage data through March 2023. without first receiving direction from Congress, the ABA, NDBA
and the 51 state bankers associations said in a comment letter. The
Read more: https://www.consumerfinance.gov/about-us/newsroom/ Federal Housing Finance Agency issued the RFI in May following
cfpb-and-fhfa-release-updated-data-from-the-national-survey-of- the release of an agency report on the future of the FHLB system,
mortgage-originations-for-public-use-2024/
which recommended that the FHFA clarify the system’s mission

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