New Changes to Section 19 Raise Questions for De Minimis Offenses, Regulation Z

Recently enacted changes to Section 19 of the Federal Deposit Insurance Act (Section 19) eased the restrictions on financial institutions when hiring individuals with criminal records, but the changes left some open questions regarding (i) the “de minimis” standard, and (ii) whether the changes to Section 19 effectively amended the Consumer Financial Protection Bureau’s (CFPB) Regulation Z (Reg Z), which applies to loan originators through Reg Z’s incorporation of Section 19 by reference.