The annual meetings of the Bankers Compliance Task Force (BCTF) supported by Jones Walker LLP were held in Collierville, Tennessee, and Flowood, Mississippi, on April 21 and 23, respectively. A wide range of topics were covered, but the focus was primarily on fraud and risk management, including check fraud, elder financial exploitation, BSA/AML/CFT updates and proposals, the new Mississippi law related to deposits made in cryptocurrency kiosks, and the many recent proposals and final rules from the various regulatory agencies. The group also received a Tennessee banking update from JoAnn Schumann of the Tennessee Department of Financial Institutions and a Mississippi banking legislation update from Eric Bennett of the Mississippi Bankers Association.
Mr. Bennett informed the group that Mississippi recently passed a law that will regulate cryptocurrency kiosks effective July 1, 2026. Pursuant to the new law, the Mississippi Department of Banking and Consumer Finance will have licensing and regulatory authority over cryptocurrency kiosk operations, including the ability to shut down kiosks involved in multiple violations. The law includes transaction limits and refund opportunities for new customers. For new customers, there is a transaction limit of $1,000 and an aggregate limit of $5,000 for 14 days. New customers will be prohibited from making a second transaction for 96 hours after an initial transaction is conducted. During that time period, the funds from the initial transaction will be held in a non-interest-bearing account. There will be a $7,500-per-day transaction limit for existing customers.
New customers will also be able to get a full refund within the first 96 hours of making an initial transaction. After this time period expires, full refunds will be issued to new customers for all transactions made within the initial 14-day time period if the customer contacts the kiosk operator and law enforcement to report that he or she was fraudulently induced to engage in the transaction and submits proof of the fraud, such as a police report or an affidavit. The law also includes additional protections for cryptocurrency kiosk users who are 60 years of age or older.
The meeting also included a review of the newly finalized changes to Regulation B related to disparate impact liability, discouraging an applicant, and Special Purpose Credit Programs as well as the still (for now) proposed changes to the small business data collection rules. The final changes to Regulation B eliminated liability related to disparate impact pursuant to the previously issued Executive Order “Restoring Equality of Opportunity and Meritocracy.” Disparate impact discrimination occurs when a seemingly neutral policy has a potentially discriminatory effect on a protected group; no discriminatory intent has to be proven for disparate impact to occur.
A second change to Regulation B is a change to the interpretation of what are considered to be actions that discourage an application. Under the new interpretation, which is intended to limit the application of the Regulation B provision, discouraging an applicant occurs when a written or oral statement is directed at or to an applicant or prospective applicant and the creditor knows or should know that the statement would be discouraging. Finally, there are changes to the requirements for Special Purpose Credit Programs that are more restrictive relating to the written plans and benefiting groups.
BCTF Meeting Dates
Please join us for one of our future BCTF meetings supported by Jones Walker. The remaining 2026 meetings are scheduled for the dates below in each location.
Flowood, Mississippi
- Thursday, August 27
- Thursday, November 5
Collierville, Tennessee
- Tuesday, August 25
- Tuesday, November 3
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