Since the November elections, much of the talk here in Washington, D.C. has been on preparing for a divided Congress. While many believe that the partisan divide will grow in 2019, this does not mean that all bank-related public policy proposals will be stuck in neutral. In fact, when it comes to regulatory reforms promulgated by federal agencies, there could be some significant and welcome news for financial institutions. Below, are my predictions (they’re more like educated guesses) on some important issues of interest to the banking industry. The FCC Will Issue a Major Declaratory Ruling on the Telephone Consumer Protection Act (TCPA) This past year has been one of promise and progress for those waiting on TCPA reform. In March, the U.S. Court Appeals for the District of Columbia vacated key parts of the Federal Communications Commission (FCC) 2015 TCPA Order, which had created much confusion and sparked increased litigation. This month, the FCC approved the creation of a National Reassigned Number Database to address the nearly 100,000 wireless numbers that are reassigned each day. While the database is not expected to be operational for several years, the FCC did provide for a safe harbor that will protect those that leverage the database from TCPA liability. The next step? I expect the FCC to issue a declaratory ruling in the first half of 2019 that will provide much needed clarity around the definition of Automatic Telephone Dialing System. This will lead to a favorable development for consumers who opt-in and businesses that utilize technology like FICO’s Customer Communication Services to communicate important information to their customers via their cellphones. The BCFP Will Finally Release a Proposed Rule Governing Debt Collection We have been talking about this for several years but I believe we are now just a few months away from the Bureau of Consumer Financial Protection issuing a Notice of Propose Rulemaking aimed at modifying the more than 40-year old Fair Debt Collections Practice Act. The proposed rule will focus on third-party collectors, addressing issues such as communication practices and consumer disclosures. When will this happen? The latest fall 2018 rulemaking agenda indicates that the BCFP will issue the rule by March. I believe this will slip a few months but by June 2019 the proposed regulations will finally be available for public review and comment. AML/BSA Reform Talks Will Intensify but Meaningful Changes Will Have to Wait Bank Secrecy Act/anti-money laundering (BSA/AML) regulatory reforms are top of mind for regulators and legislators. This month, a group of federal agencies including the Federal Reserve, OCC, FDIC and the Financial Crimes Enforcement Network (FinCEN) issued a joint statement which encourages banks to consider, evaluate, and responsibly implement innovative solutions to BSA/AML compliance. Members of Congress have also been focused on BSA/AML reforms. In June, House members Blaine Leutkeymeyer (R-MO) and Steve Pearce (R-NM) introduced legislation that included an increase in the thresholds for currency transaction reports (CTRs), from $10,000 to $30,000, as well as suspicious activity reports (SARS), from $5,000 to $10,000. These are two areas where financial institutions are spending billions of dollars a year on compliance and have been looking to ensure their extensive efforts are properly calibrated to provide regulators with meaningful insights. On this topic, a FICO colleague recently wrote a blog post noting that FinCEN received more than 2,000,000 SARs in 2017, and that by employing cognitive analytics FinCEN could gain new insights from these reports. Where is BSA/AML reform headed in 2019? Legislative efforts will prove challenging. While there is some agreement to address the issue of beneficial ownership, other reforms have divided Republicans and Democrats. Despite extensive, ongoing discussions of BSA/AML reforms among regulators, a recent Senate Banking Commit