April 13, 2017
In This Issue
Quick Links
ComplySight: FREE Recorded Webinars
Upcoming Educational Events
April 26

April 26

May 10 & 11

For a complete listing of educational opportunities available from LCUL and to register, visit the League website and click on "Education"
Compliance Toolkit
The BSA Officer's Toolkit contains tools to help manage your institution's BSA/AML program. It is designed to help you revamp and revitalize your BSA program before the examiners arrive.

Toolkit is provided by GetTechnical Inc. 

ComplySight: a complete compliance management and tracking system 

What can ComplySight do for your credit union?  It is central site that allows your credit union to:
  • review regulations and laws to assess the level of compliance within your own organization;
  • manage regulatory requirements and the associated internal organizational communications;
  • assign and track the activities needed to achieve or maintain compliance; and
  • keep current on regulatory alerts and updates. 
 
ComplySight Training is Available!
Not sure how to get started, or want a refresher on how to use ComplySight? Or are you interested in seeing more of how ComplySight works?  We are excited to make available recorded webinars to help you get the most out of ComplySight! We currently have seven training modules available!  The ComplySight training webinars are available at any time, and registration is not required. Click here to start training today !
 
ComplySight: 30 Day Free Trial!
If you're interested in a "trial run" of ComplySight, League InfoSight is offering a free, 30-day trial so you can see the benefits first-hand. It's easy to get started.   Just visit us online and click on Free Trial Offer . Don't forget to use promo code: FREETRIAL810. 
InfoSight Highlight: FFIEC Cybersecurity Assessment Tool 

Overview
The Assessment consists of two main components; the Inherent Risk Profile and the Cybersecurity Maturity. The Inherent Risk Profile helps the institution understand how their products and services contribute to the institution's overall inherent risk and whether specific categories pose more risk than others. The Cybersecurity Maturity component contains assessment factors and individual declarative statements across five main domains to identify specific controls and practices. While management can determine the institution's maturity level in each area, the Assessment is not designed to identify an overall cyber security maturity level.

CFPB provides HMDA coverage chart  

To assist with determining if your credit union will need to report HMDA activity under Regulation C, effective January 1, 2018, the CFPB has provided the following chart .  Please note that it is not intended to be a substitute for the regulation or its commentary, but is a quick reference guide.
 
Source: CFPB
Consumer Compliance Rating System 
 
NCUA issued Letter to Credit Unions 17-CU-02 providing guidance on updated compliance risk indicators.  NCUA Field staff will begin using the updated list of indicators for any supervisory evaluations of compliance risk going forward.  These risk indicators incorporate the principles of the FFIEC's Interagency Consumer Compliance Rating System (CCRS). You may recall that the CCRS is an interagency framework for evaluating an institution's ability to manage consumer compliance risk and to prevent consumer harm.  NCUA incorporates the framework into its Risk Focused Examination Program.  Remember, a credit union's compliance management system is to proactively manage compliance risk by self-identifying and self-correcting any identified compliance deficiencies. The updated compliance risk indicators detailed in NCUA's recent letter focus on three areas and specific factors within each area.  

Source: CUNA Blog
CUNA weighs in on FinCEN's proposed changes to the SAR 

On March 29, CUNA  filed a letter  with FinCEN regarding proposed technical revisions to the Suspicious Activity Report (SAR). While our concerns with the proposed updates were minimal, we used the opportunity to raise ongoing concerns with BSA/AML requirements with FinCEN. 
 
 
Source:  CUNA Removing Barriers
Fiduciary rule applicability date delayed 60 days 

The Department of Labor's Employee Benefits Security Administration has submitted for Federal Register publication on Friday, April 7, 2017, a  final rule  delaying the Applicability Date of its rule on Fiduciary Conflicts of Interest -- Retirement Investment Advice, and selected other changes, from April 10, 2017, for 60 days, to June 9, 2017. The effective date of this final rule (delaying the Availability Date and certain other provisions) is April 10, 2017.
 
Source: DOL
Compliance Lagniappe is bi-monthly newsletter for affiliated credit unions of 
the Louisiana Credit Union League. For more information or for compliance inquires, please contact the League's compliance department at compliance@lcul.com.