Washington Report 360 | August 9, 2019

Fed will develop a real-time payments system; CFPB shared test findings on first NAL; COSO ERM framework guidelines.

Key highlights

  • The Federal Reserve will develop a real-time payments system to be launched by 2024; the Federal Reserve is also considering expansion of the Fedwire Funds and National Settlement services.
  • CFPB shared test findings on its first No Action Letter (NAL) for a provider that utilizes alternative data and machine learning in its credit underwriting and pricing model. The testing indicated increased access to credit and no fair lending disparities. The NAL is not an endorsement of any variables or models, specifically references Reg B/ECOA, and requires model risk management and a compliance plan.
  • COSO is expected to publish guidelines on how to apply its enterprise risk management framework to cyber security; how to enhance risk-appetite statements; and how to better manage risk and compliance. COSO will also publish board directors guidance on managing strategic risks.

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