Today’s pace of change demands active engagement from every compliance function. Professionals at Forvis Mazars discussed regulatory changes in the third quarter of 2026, enforcement actions, and best practices in our webinar, “Compliance Conversations With ProBank Education Services: Q3 2026.” Topics summarized below include regulatory vigilance, suspicious activity report (SAR) reporting, Financial Crimes Enforcement Network (FinCEN) priorities, and emerging fraud schemes.
Regulatory Vigilance
Agencies have published a heavy volume of proposals and final rules, and compliance teams cannot afford to watch passively. The final Equal Credit Opportunity Act (ECOA)/Regulation B rule, issued April 22 and effective July 21, states that ECOA does not recognize disparate impact liability and narrows the focus to overt discouragement of minority applicants. The Section 1071 final rule, effective June 30, raised the covered institution threshold from 100 to 1,000 originations, lowered the small business revenue threshold to $1 million or less, and cut several discretionary data points. The Consumer Financial Protection Bureau (CFPB) also issued June 8 guidance on weighing immigration status within the ability-to-repay analysis and opened a request for information on easing Truth in Lending Act (TILA) and Real Estate Settlement Procedures Act (RESPA) integrated disclosures (TRID) burdens.
More proposals remain open. The FDIC proposed lifting the small-versus-large asset threshold from $10 billion to $30 billion and allowing insured depository institutions to share confidential information with affiliates without prior authorization. Four agencies, plus FinCEN, floated permitted payment stablecoin issuer rules requiring Bank Secrecy Act (BSA), anti-money laundering (AML), and customer identification program compliance alongside confidential reporting. The Financial Stability Board proposed sound practices for responsible artificial intelligence (AI) adoption, and the Federal Financial Institutions Examination Council (FFIEC) proposed strengthening the CAMEL/UFIRS rating system. We recommend tracking these items; submitting comments before deadlines close; and routing cost-relevant proposals, such as the FDIC assessment charge, to your chief financial officer.
Evolution of SAR Reporting & FinCEN Priorities
SAR reporting has moved far beyond structuring and routine money laundering. First-quarter filings for banks, savings institutions, and credit unions reached 565,135, part of more than 1 million across all eight filing groups. Inconsistent transactions—those with no apparent economic, business, or lawful purpose—now rank first among reports, making up 15% of filings when combined with inconsistent source of funds. Traditional structuring fell to fourth. Suspicious wires climbed above 9%, while check fraud dropped to sixth.
FinCEN’s stated priorities reflect this shift. Fiscal fuel theft and fuel smuggling have become the largest non-drug illicit revenue source for cartels. Non-work-authorized populations raise concerns tied to identity theft and payroll tax fraud that can fund criminal and terrorist organizations. Human trafficking syndicates were expected to follow the FIFA World Cup 2026, with red flags detailed in FinCEN’s May 11 notice.
Creative & Emerging Fraud Schemes
Fraudsters are growing more creative. Pet scams use AI-generated distress photos and callers posing as law enforcement or animal hospital staff. Government imposter scams now include fake photo IDs sent by text to appear legitimate. The financial toll is steep, with consumers losing $3.5 billion to imposter scams in 2025. Social media scams produced more in losses last year than any other contact method used by scammers. Educating customers, strengthening first-party fraud detection, and applying Nacha’s updated monitoring rules are among the strongest defenses.
How Forvis Mazars Can Help
As a leading provider of continuing education programs for financial professionals, ProBank Education Services trains thousands of financial industry employees annually through our tailored programs. If you have any questions or need assistance, please contact us.