In the evolving landscape of banking compliance, financial institutions continue to monitor developments related to fair lending, small business data collection, and Bank Secrecy Act/Anti-Money Laundering (BSA/AML) expectations. A recent webinar with ProBank Education Services highlighted how regulators are moving from broad policy signals toward more formalized rulemaking. Agencies such as the Consumer Financial Protection Bureau (CFPB), FDIC, the Office of the Comptroller of the Currency (OCC), and the Financial Crimes Enforcement Network (FinCEN) are refining compliance frameworks, reporting expectations, and supervisory focus areas. The sections below summarize three notable federal updates that may shape current compliance priorities.
What Are CFPB Proposed Revisions to Regulation B?
The CFPB’s proposal to revise Regulation B reflects a shift from reliance on executive orders toward more structured rulemaking. The changes are intended to align the regulation with the removal of disparate impact analysis from fair lending examination procedures. This represents the CFPB’s continued effort to clarify how examiners evaluate potential discriminatory practices.
The proposed revisions emphasize discouragement standards that focus on direct statements rather than indirect outcomes, signaling a narrower interpretation of what may be considered discriminatory communication. The proposal also outlines new limitations for special purpose credit programs (SPCPs), particularly for for‑profit institutions. These restrictions would limit the use of protected class characteristics in establishing eligibility criteria, marking a significant development in the fair lending environment. Although the rule remains in the proposal stage, it illustrates a clear federal movement toward defining fair lending obligations through more detailed regulatory language.
How Has CFPB Narrowed the Approach to Section 1071 Data Collection?
Section 1071 remains active despite delays in implementation. The CFPB has indicated that a narrower initial data‑collection scope is the most effective approach to achieve the goals of the statute: generating meaningful, high-quality data on small business lending while reducing disruptions to credit access. This approach is designed to reduce pressure on financial institutions and reduce the burdens on small businesses required to provide the data.
Additional guidance and possible revisions are expected, making ongoing monitoring important. The CFPB’s posture aligns with a broader regulatory emphasis on supporting accessible credit environments, particularly for smaller commercial borrowers. CFPB continues to focus on data integrity, visibility into fair lending performance, and balancing supervisory goals with operational realities.
What Are FinCEN’s Updated FAQs on SAR Filing & AML/CFT Expectations?
FinCEN recently issued updated FAQs addressing suspicious activity report (SAR) filings and anti-money laundering and combating the financing of terrorism (CFT) program elements. These updates reaffirm expectations for risk-based and reasonably designed compliance programs. While no regulatory requirements have changed, the FAQs are intended to support more effective allocation of compliance resources for institutions and enhance the usefulness of information provided to law enforcement and other BSA stakeholders.
Key clarifications include guidance on structuring‑related SARs, expectations for continuing filings, and when institutions may document decisions not to file a SAR. Although documentation is not explicitly required, examiners may continue to view it as supportive evidence of program effectiveness.
How Forvis Mazars Can Help
These regulatory updates illustrate how agencies are refining expectations to create more clarity, support stronger compliance processes, and respond to emerging risk trends. Professionals with relevant experience at Forvis Mazars can assist you in interpreting these developments, strengthening compliance programs, and supporting efforts to navigate shifting supervisory landscapes. For additional insight, you may contact a member of the Financial Services team.
Join us in person to learn more about how we can help your financial institution tackle issues. At our annual 2026 AML/CFT/BSA & Fraud Compliance Conference from May 12 to May 14 in Sandestin/Miramar Beach, Florida, we’ll identify current and emerging Anti-Money Laundering (AML), Countering the Financing of Terrorism (CFT), Bank Secrecy Act (BSA), and fraud risks.