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ABA Survey Shows Need for CFPB to Address ‘Rolling Delinquencies’ (10/27/14 ) Making a case for the Consumer Financial Protection Bureau to clarify how a “rolling delinquency” triggers the 120-day delinquency period required before a mortgage servicer can begin foreclosure, ABA last week shared survey data with the Bureau showing that these delinquencies are not uncommon and that the industry handles them in different ways.

FATF Discusses De-Risking at FATF Plenary (10/24/14) FATF reminds financial institutions to use a risk-based approach rather than de-risking. ABA and ABA's subsidiary, BAFT are long-time advocates of a risk-based approach to implement effective AML/CFT controls. ABA's 2013 letter to BASEL reiterates our support of FATF's endorsement of a risk-based approach, but notes that the burden should not shift to banks in a way that precludes the bank from making its own judgment about its tolerance for risk.

 

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