Page 9 - August 22, 2024 Bulletin

aRTiCLeS

In a statement, CrowdStrike CEO George Kurtz urged customers 68% of HSA holders live in a zip code with a median household
with questions to reach out to their CrowdStrike representative or income of less than $100,000.
technical support.
Read more: https://www.devenir.com/research/2023-devenir-hsa-
“We know that adversaries and bad actors will try to exploit events council-demographic-survey/
like this,” Kurtz said. “I encourage everyone to remain vigilant and
ensure that you’re engaging with official CrowdStrike representatives. Paycheck Advance Products
Our blog and technical support will continue to be the official Subject to Truth in Lending Act,
channels for the latest updates.”

Read more: https://www.crowdstrike.com/falcon-content-update- Reg Z
remediation-and-guidance-hub/ The CFPB has proposed an interpretive rule declaring that paycheck
advance, including earned wage access, products are consumer loans
FDIC Finalizes Rule Easing Bank subject to the Truth in Lending Act and Regulation Z. The bureau
Hiring Restrictions also published a related report on employer-sponsored paycheck
advance loans that alleged that the “typical” loan carries an annual
The FDIC recently issued a final rule easing restrictions on bank percentage rate of more than 100%. The bureau set an Aug. 30
hiring of job candidates with criminal histories. deadline for comments on the proposed interpretive rule.

Section 19 of the Federal Deposit Insurance Act generally prohibits According to the CFPB, the interpretive rule states that consumers
banks from hiring a person convicted of an offense involving who use paycheck advance or “earned wage” products incur a “debt”
dishonesty, breach of trust or money laundering without first seeking and therefore the funds advanced to the consumer are “credit.” The
consent from the FDIC. But in 2022, President Biden signed into provider must calculate and disclose the finance charge associated
law the Fair Hiring in Banking Act, which created several exclusions with the advanced funds, including any “tips” the consumer chooses
to the consent requirement. The FDIC’s final rule implements—and to leave for the provider and expedited funds delivery fees, as well
expands upon—the provisions of the Fair Hiring in Banking Act. as comply with other provisions of Regulation Z. The rule replaces
a 2020 advisory opinion that addressed employer-sponsored EWA
The final rule specifically notes that crimes prosecuted by foreign products where the consumer does not pay any required or voluntary
authorities are within the scope of Section 19; provides a full fee to the provider.
definition of “certain crimes involving controlled substances” for
Section 19 purposes; and provides much-needed certainty regarding As for the report on employer-sponsored advances, the CFPB
offenses too small to justify a criminal convention (de minimis estimated that the number of transactions processed by providers
offenses). grew by more than 90% from 2021 to 2022, with more than
7 million workers accessing approximately $22 billion in 2022.
Read more: https://www.fdic.gov/system/files/2024-07/fr-revisions-to-
the-fdics-section-19-regulations.pdf Roughly 90% of workers paid at least one earned wage product-
related fee out of the companies surveyed, according to the bureau.
More Than 61 Million Americans The APR for a typical employer-partnered earned wage product
transaction was 109.5%, based on the CFPB sample.
Covered by Health Savings Read more: https://files.consumerfinance.gov/f/documents/cfpb_
Accounts paycheck-advance-marketplace_proposed-interpretive-rule_2024-07.pdf

More than 37 million health savings accounts existed at the end FDIC Releases FAQ on New
of 2023, providing coverage to more than 61 million Americans,
according to a new survey by Devenir and the American Bankers Signage Rule
Association’s HSA Council. The survey found that millennials
continue to be major users of HSAs, with 30% of accounts held by The FDIC has released a list of questions and answers about its new
people in their 30s. rule regarding the display of the official FDIC sign in banks and
bank digital channels, as well as the misrepresentation of deposit
Account holders ages 55 or older had accumulated more than $52 insurance status. The FAQ will be periodically updated.
billion in their accounts at the end of 2023, which was a 20%
increase from the previous year, according to the survey. The average Read more: https://www.fdic.gov/deposit-insurance/questions-and-
account balance for the age group was $5,739. At the same time, answers-related-fdics-part-328-final-rule

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