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Have a question for your peers?
Email the Lagniappe Listserv at
[email protected]
t
o get input on compliance related issues, share best practices, or share policies, procedures and the latest in fraud awareness.
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ComplySight: FREE Recorded Webinars
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Recorded Webinars - Watch on Demand!
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Upcoming Educational Events
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For a complete listing of educational opportunities available from LCUL and to register, visit the
League website and click on "Education"
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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.
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League InfoSight announces ComplySight enhancement
ComplySight adds complaint management capabilities at no additional cost
League InfoSight, a collaborative effort of 15 credit union leagues/associations and the Credit Union National Association (CUNA), announced today that it has added the ability to log and manage complaints to ComplySight, its self-assessment tool credit unions can use to grade themselves on compliance with federal regulations.
This enhancement, added with no extra fee for users, reinforces the organization's ongoing effort to provide effective and affordable compliance products to credit unions.
"Our goal is to continually enhance our products to be best-in-class, making sure we are keeping pace with credit unions' compliance needs," said League InfoSight CEO Glory LeDu. "Adding the ability to log, assign and store complaints within ComplySight adds even more value to a sophisticated, cost-effective tool that assists credit unions in maintaining an effective compliance management system - something regulators expect."
Along with its new capacity to maintain and store complaints, ComplySight allows credit unions to attach and store documents that evidence compliance, assign potential deficiencies or compliance reviews to relevant employees and receive alerts for new or revised regulations. The cost for ComplySight is based on a credit union's asset size.
"ComplySight was designed to be versatile with multiple access levels and consulting so credit unions can customize, utilize and create the system based on their individual needs and relevant products/services," added LeDu.
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InfoSight Highlight- Servicemembers (and Dependent) Consumer Lending (Military Lending Act)
As required by the John Warner National Defense Authorization Act for Fiscal Year 2007 which added 10 USC 987, the Department of Defense (DOD) issued a regulation that implements the Military Lending Act (MLA) regarding the terms of consumer credit extended by creditors to service members and their dependents.
In July 2015, the changes were made that impacted the MLA and became effective on October 1, 2015. Credit unions were required to comply with the changes on October 3, 2016. Credit unions should have policies and procedures in place to determine if their new borrower(s) are considered "covered borrowers" under the MLA. If the borrower(s) are determined to be covered under the rules, the credit union must also determine if the loan a "covered loan." If the borrower(s) and the loan are both covered under the rules, the credit union should understand their Military Annual Percentage Rate (MAPR) limitations as well as the required disclosures that need to be provided prior to consummation.
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Why Bank Secrecy Act reporting matters
Five examples of law enforcement actions from BSA reporting
Credit union employees responsible for Bank Secrecy Act (BSA) compliance and reporting feel the burden of their work, but they don't always see the connection to law enforcement actions.
But BSA reporting does have real-world implications, according to the Financial Crimes Enforcement Network (FinCEN).
Click here to read more.
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Top 10 ways to protect yourself in the wake of the Equifax data breach
Whether or not you are among the millions of people affected by the recent Equifax data breach, there are several steps you can take to respond when your personal information is exposed in a data breach.
We outlined several identity theft tips for you last week
. Since then, people have been asking many questions and we will continue to work to provide answers-or point people to other resources that may help make the situation clearer.
Source: CFPB
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Customer Due Diligence for all accounts
The Financial Crimes Enforcement Network's (FinCEN) new customer due diligence (CDD) requirements for business accounts are effective May 18, 2018, and CUNA's compliance staff has received a number of questions. A recent
CompBlog post
examines CDD procedures and requirements.
Bank Secrecy Act regulations do not have specific provisions for CDD requirements for non-business accounts, credit unions generally rely on the Federal Financial Institutions Examination Council's (FFFIEC) examination manual for guidance.
The CDD guidance recommends credit unions:
- Know the true identity of its members;
- Gain an understanding of a member's normal and expected transaction activity, based on their occupation or business operations to better determine if something is suspicious, and whether a suspicious activity report (SAR) needs to be filed;
- Keep an eye out for indicators of potential changes in the member's risk profile. For example a change in employment, a change in business operations, or unexpected account activity; and
- Include procedures to periodically monitor the member's information.
According to the examination manual, a credit union's Bank Secrecy Act/anti-money laundering (BSA/AML) program should include due diligence procedures that:
- Are commensurate with the credit union's BSA/AML risk profile, with particular attention paid to high-risk members;
- Contain a clear statement of management's overall expectations, as well as management's expectations regarding staff responsibilities;
- Ensure the credit union possesses sufficient member information to implement an effective suspicious activity monitoring system;
- Provide guidance for documenting analysis associated with the due diligence process, including guidance for resolving issues when insufficient or inaccurate information is obtained; and
- As a best practice, ensure the credit union maintains current member information.
Once credit unions have identified high-risk members, it should consider obtaining specific information, including source of funds, occupation, place of employment and others.
Source: CompBlog
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Compliance Calendar
October, 2017
January, 2018
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