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 .
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Compliance and Advocacy News and Highlights
FinCEN Making More Changes to CTR Filing Instructions
Effective April 6, 2020 (September 1, 2020 for batch e-filers) FinCEN ruling FIN-2020-R001 replaces and rescinds two rulings: FIN-2006-R003, Currency Transaction Reports on Sole Proprietorships, Feb. 10, 2006, and FIN-2008-R001, Reporting of Certain Currency Transactions for Sole Proprietorships and Legal Entities Operating Under a “Doing Business As” (”DBA”) Name, Jan. 25, 2008.

The rescinded rulings were based on the now obsolete FinCEN Form 104. The Financial Crimes Enforcement Network (“FinCEN”) is issuing this administrative ruling to clarify the Currency Transaction Report (“CTR”), FinCEN Form 112 filing obligations when reporting transactions involving sole proprietorships. In an effort to both enhance regulatory efficiency and provide complete and accurate CTR data to law enforcement, FinCEN is clarifying the requirements of financial institutions reporting on currency transactions involving sole proprietorships and legal entities operating under a “doing business as” (“DBA”) name when filing the current CTR FinCEN Form 112.

Source: FinCEN
CFPB Conducting TRID Assessment Industry Surveys
The CFPB is currently assessing the TILA-RESPA Integrated Disclosures (TRID) Rule. The assessment of major rules within five years after final action is required by the Section 1022(d) of the Dodd-Frank Act.
As part of the TRID assessment, the CFPB is conducting three industry surveys : loan originators, loan officers, and closing companies. These surveys will help the CFPB learn about the experiences of industry participants.

Please note that participation is voluntary. However, the surveys will assist the CFPB in understanding the effects of the rule and responses from community-based lenders will provide the CFPB with a better picture of how those entities were affected by the TRID Rule.

The deadline to submit a survey response is March 6, 2020.

Source: CFPB
What are “Trusted Identities”?
Governments across the world have been working to promote the development of “trusted identities” that will:
  • Enhance privacy,
  • Improve security,
  • Be interoperable, and
  • Include easy-to-use digital identity solutions.

The idea of using digital identification has been popping up across the U.S. for the past several years. In 2014, Iowa’s Department of Transportation introduced the idea to test a Digital Driver’s License (DDL), while Louisiana launched their DDL in July 2018. Several other states have passed legislation to study, develop, create task forces, and/or issue digital driver’s licenses. 

The federal government has also been studying the use of digital IDs. In 2016, the U.S. Commerce Department's National Institute of Standards and Technology (NIST) awarded a grant to further the development of trusted identities based on state-issued DDLs. Idaho, Colorado, Maryland, Washington D.C. and Wyoming participated in the pilot program. The Department of Transportation has also been reported to be working on an app to support these new IDs.

As with any digital technology, there is a need for caution. Although digital driver’s licenses are expected to come with the usual safeguards, such as a PIN and password, cybersecurity experts warn that there is no fail-safe technology, especially on a smartphone.

Source: CUNA Compliance Blog
Articles of Interest
Pending Comment Calls
CUNA's Advocacy Resources
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
There's more available from InfoSight
InfoSight content is available anytime to get sample policies, links to federal regulations and summaries of issues that are hot-topics at your credit union. 
 
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