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
Loans and Leasing
Because of recent NCUA amendments to appraisal rules found in NCUA Part 722, the   Appraisals Topic   has been updated to include new content. The revisions amend and add to the definitions section of the rule and provide for additional exemptions for rural areas and for commercial transactions. 
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Our Compliance Connection channel provides credit unions with detailed information on the regulatory issues they face in the ever-changing world of compliance.
Compliance News
NCUA Appraisal Final Rule Now in Effect
In their July meeting, NCUA’s Board approved  a final rule effective October 22, 2019, that amends the agency’s real estate appraisal requirements for certain transactions as part of the  NCUA’s regulatory reform agenda .

“This rule is part of a commonsense approach to regulation that will help put more resources into our communities,” NCUA Board Chairman Rodney E. Hood said. “Rethinking the appraisal rule is an example of regulatory reform that is positive and can help boost economic activity and job creation, particularly in some of our nation’s more hard-pressed areas.”
 
The final rule accomplishes four agency objectives:
  • Increases the threshold for required appraisals in commercial real estate transactions from the current $250,000 to $1 million;
  • Reorganizes the appraisal regulation to make it easier to determine when a written estimate or an appraisal is required;
  • Exempts real estate transactions located in rural areas from appraisal requirements if certain conditions are met; and
  • Amends the definitions section of the rule to reflect these changes.
Fidelity Bond Requirements Now in Effect
In their July meeting, the NCUA Board also approved  a final rule  amending the agency’s fidelity bond requirements to better ensure safe and sound credit union operations and protect the National Credit Union Share Insurance Fund. The rule went into effect October 22, 2019.

  • Strengthen oversight of fidelity bond coverage by a credit union’s board of directors;
  • Create a one-year discovery period following a credit union’s liquidation;
  • Codify the Office of General Counsel’s September 2017 legal opinion permitting a natural-person credit union to extend bond coverage to certain credit union service organizations; and
  • Clarify the documents subject to the NCUA Board’s approval and require all bond forms receive approval every 10 years.

The final rule does not require a credit union’s supervisory committee to review its fidelity bond renewal
Source: NCUA
Regulators issue joint statement on digital assets
The U.S. Commodity Futures Trading Commission (CFTC), Financial Crimes Enforcement Network (FinCEN) and the SEC have issued a joint statement  to remind persons engaged in activities involving digital assets of their anti-money laundering and countering the financing of terrorism (AML/CFT) obligations under the Bank Secrecy Act (BSA):
  • AML/CFT obligations apply to entities that the BSA defines as “financial institutions,” such as futures commission merchants and introducing brokers obligated to register with the CFTC, money services businesses (MSBs) as defined by FinCEN, and broker-dealers and mutual funds obligated to register with the SEC. Among those AML/CFT obligations are the requirement to establish and implement an effective anti-money laundering program (AML Program) and recordkeeping and reporting requirements, including suspicious activity reporting (SAR) requirements.
 
Source: FinCEN
Advocacy Highlight
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 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.