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July/August 2010

Survey Question of the Week
On August 22, 2010, prepaid gift cards will be subject to a new regulation requiring new disclosure notices, restricting dormancy and periodic fees, and extending the expiration date for the funds underlying the card. How has this new regulation affected your bank’s gift card program?
We are maintaining the same/similar sales of gift card products
We are scaling back sales of gift card products
We are eliminating sales of gift card products
We are increasing sales of gift card products
We did not offer gift cards so this has no effect on us

What is the size of your institution?
less than $100 million
$100 to $500 million
$500 million to $2 billion
Over $2 billion

  • FDIC Extends Application Deadline for Safe Accounts Pilot Program (9/3/10)
    The FDIC extended from Sept. 15 to Oct. 15 the application deadline for the agency's pilot program to evaluate the feasibility of banks offering safe, low-cost transactional and savings accounts. Under the pilot program, participating institutions will offer electronic deposit accounts with product features identified in the FDIC Model Safe Accounts Template.  The accounts the pilot institutions offer will be FDIC-insured, have reasonable rates and fees, and will be subject to applicable consumer protection laws, regulations and guidance. Participating institutions will not charge fees for nonsufficient funds or overdrafts for the accounts.  Read the model accounts template. For more information, contact ABA's Cathy McTighe.
  • ABA Recommends Broader Exemptions in FinCEN Prepaid Card Rule (8/31/10)
    The Financial Crimes Enforcement Network should continue working with interested stakeholders to develop a workable regulatory regime for nonbank prepaid access products, ABA said in a comment letter on FinCEN's notice of proposed rulemaking intended to establish a more comprehensive regulatory framework for such products. The proposal -- mandated under the 2009 Credit Card Act -- covers prepaid devices such as plastic cards, mobile phones, electronic serial numbers, key fobs and other mechanisms that provide a portal to funds that have been paid for in advance and are retrievable and transferable. While the proposal would not apply to banks, ABA said that it is important to recognize the important role that banks play. The association said that it supports the proposal's exemption of products such as payroll cards, government benefit cards and others that do not present a money-laundering risk. But ABA added that the exemptions do not go far enough in recognizing the attributes of prepaid products and the controls the industry uses to minimize risks for those attributes. "To focus on real risks better, ABA recommends that the proposed exceptions be revised and expanded," the association said.  Read the letterRead the proposal. For more information, contact ABA's Rob Rowe.
  • ABA Member Trustees Encourage Servicers to Use First Look Program (8/26/10)
    ABA member banks that serve as trustees on residential mortgage-backed securitization transactions are encouraging servicers of such transactions to strongly consider using the National Community Stabilization Trust's First Look Program. "ABA's member trustees believe that working with entities such as NCST, other nonprofit entities and governmental agencies and officials is an imperative to address the foreclosure crisis and support neighborhood stabilization efforts," ABA COO Diane Casey-Landry said. As a result, sales are quicker, carrying and marketing costs for financial institutions are lower, and vandalism, further declines in property value and other risks are avoided. Financial institutions, in turn, pass on savings as pricing adjustments to local NCST buyers. Read the letter. For more information, contact ABA's Cris Naser.
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Questions? For more information, contact Grace Marasigan.