One of the benefits of your credit union's League membership is access to InfoSight--a valuable online compliance resource. This newsletter contains some timely highlights, and access to InfoSight is a benefit of League affiliation, so it is password-protected. If you have a specific compliance issue or concern, contact our Consulting Department at (800) 285-5300. Replies to this email will be directed to SVP, League Services & Regulatory Analysis Joe Guilfoy .
InfoSight Highlight
Customer Due Diligence and Beneficial Ownership
Although compliance with the final rule isn’t required until May 11, 2018, credit unions have had since May 11, 2016, to begin their compliance with the amendments to the Bank Secrecy Act that relate to these four core elements:
  1. Identification and verification of customers;
  2. Identification and verification of beneficial owners of legal entity customers, subject to certain exceptions;
  3. Development of a customer risk profile through an understanding of the nature and purpose of the customer relationship, and
  4. Ongoing monitoring for reporting suspicious activity, and on a risk basis, maintaining and updating customer information.

Several of these elements are part of the existing customer identification program (CIP) rules, with others implied through suspicious activity reporting (SAR) requirements. The beneficial ownership identification requirement is new and not part of any existing rule.

Click here to view the topic , and to ensure your credit union is in compliance.
Compliance Videos
Compliance Outlook for Q4 2017
In this video, Glory LeDu provides a brief summary of the key changes of the new HMDA rules that became effective January 1, 2018. You won’t want to miss this important overview!

Just a reminder that Compliance videos since 2016 can be found on YouTube at the Compliance Connection channel , where they are generally updated quarterly.
Compliance News
Bureau adds HMDA LAR tool and updates resources
The CFPB has updated its  Resources for HMDA filers   page, adding a   2018 LAR Formatting Tool , and making minor updates to the   2018 Filing Instructions . The 2018 LAR Formatting Tool is designed to assist financial institutions create an electronic file that can be submitted to the HMDA platform. It can be used for data collected in 2018 and reported next year.

The Bureau also updated its   Reportable HMDA Data: A regulatory and reporting overview reference chart . If you previously downloaded the 2018 Filing Instructions and/or the reference chart, we recommend you replace them with the newer versions
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Source: CFPB
Weekly Regulatory Advocacy Report
The Weekly Advocacy Report provides links to information about a number of recent League, CUNA and NCUA regulatory and advocacy activities. 
   
Upcoming Education Sessions
The League has several education sessions coming up. Several focus on compliance issues. They are listed in calendar format on the League website.
   
League Consulting Department Staff
(800) 285-5300
Compliance Calendar
February
  • February 19, 2018: President's Day - Federal Holiday
March
  • March 16, 2018: Same-day ACH (NACHA) – Phase 3 of the implementation period for the rule.
April
  • April 1, 2018: Prepaid Accounts under the Electronic Fund Transfer Act/Regulation E and the Truth In Lending Act/Regulation Z (Date Extended)
  • April 29, 2018: 5300 Call Report Due to NCUA
May
  • May 11, 2018: Customer Due Diligence – CDD (FinCEN) – Effective date
  • May 28, 2018: Memorial Day - Federal Holiday
July
  • July 4, 2018: Independence Day - Federal Holiday
  • July 29, 2018: 5300 Call Report Due to NCUA
September
  • September 3, 2018: Labor Day - Federal Holiday
October
  • October 8, 2018: Columbus Day - Federal Holiday
November
  • November 12, 2018: Veterans Day (observed) - Federal Holiday
There's more available from InfoSight
InfoSight content is available from the League's website . Visit anytime to get sample policies, links to federal regulations and summaries of issues that are hot-topics at your credit union. 
 
Access to InfoSight is a benefit of League affiliation, so it is password-protected. If you don't have a password or if you have forgotten yours, click on the tan "Log In" button in upper right corner of the site; a box will open. Click on the blue wording to get your password.