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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Just a reminder that the
Compliance Calendar
in InfoSight has important dates you need to know to be compliant with upcoming regulatory changes, holidays, and important effective dates! Check it out today!
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Compliance Connection Videos
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Compliance training educates your staff on the laws and/or regulations applicable to their role in the credit union. A proper understanding of compliance helps to minimize risk, maintain the credit union’s reputation and provides a better environment for your staff and members. Our
Compliance Connection channel
is a great resource to bring everyone up to speed changes to laws and regulations, including when the changes take effect and what your credit union needs to do to be in compliance.
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FinCEN Issues Important Update for BSA Discrete and XML Batch E-Filers
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Guidance for filing CTRs has been updated by
FinCEN in a recent notice
when more than one “role” (Item 2 on the CTR) applies to the person being listed in Part I.
FAQ #16
has been updated to reflect these changes and – according to the notice:
This change will potentially require update to software used to create batch files to comply with this instruction change and in view of this FinCEN proposes a target date for updating batch filing of October 1, 2019, with a mandatory effective date of February 1, 2020.
Source: FinCEN
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NCUA Extends Deadline to Qualify for Streamlined CDFI Application
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The National Credit Union Administration has extended the deadline for federally insured, low-income credit unions that want to become certified Community Development Financial Institutions to apply for qualification to use the agency’s streamlined CDFI certification process.
The deadline is now Nov. 30. This will be the final opportunity to take advantage of the streamlined certification process in 2019.
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NCUA Posts Final Rule on Audits and Verifications
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The NCUA has published a
final rule
amending its regulations governing the responsibilities of a federally insured credit union to obtain an annual supervisory committee audit of the credit union. The final rule implements recommendations outlined in the agency's Regulatory Reform Task Force's Regulatory Reform Agenda and will provide additional flexibility to FICUs. Specifically, the Board is: replacing the Supervisory Committee Guide with a simplified appendix to the part (12 CFR part 715); eliminating two audit types that FICUs seldom use; and eliminating a specific deadline for outside, compensated persons to deliver written audit reports to FICUs. The amendments to 12 CFR 715 will be effective January 6, 2020.
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NCUA Posts Final Rule on FCU Bylaws
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The NCUA Board has published a
final rule
to update, clarify, and simplify the federal credit union bylaws. The final rule updates and conforms the bylaws to legal opinions issued by the NCUA's Office of General Counsel and provides greater flexibility to federal credit unions (FCUs). The final rule also makes other changes that are designed to remove outdated or obsolete provisions. The rule, which amends NCUA regulations in 12 CFR parts 701 and 746, will be effective January 2, 2020.
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HMDA Releases Filing Instructions Guide for HMDA data Collected in 2020
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The
2020 Filing Instructions Guide
(FIG) is a compendium of resources to help you file HMDA data you collected in 2020 with the Bureau of Consumer Financial Protection in 2021.
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CU Trades Endorse NCUA ‘Second Chance’ Initiative
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According to a
recent article from Credit Union Times
, people who have been convicted of minor offenses as young adults should be able to work at credit unions without the approval of the NCUA board, credit union trade groups said, in supporting the agency’s Second Chance initiative.
“The Board recognizes that many Americans face hiring barriers due to a criminal record, a great number of which are not violent or career criminals, but rather people who made poor choices early in life who have since paid their debt to society,” the agency said, when the board proposed the initiative earlier this year.
Under the proposal, credit unions would no longer be required to submit applications to the agency to employ people who have bounced checks for a moderate amount or have been convicted of “small dollar simple theft, false identification, simple drug possession, and isolated minor offenses committed by covered persons as young adults.”
“Offering second chances to those who are truly penitent is consistent with our nation’s shared values of forgiveness and redemption,” the agency said.
The plan would decrease the regulatory burden for credit unions, while continuing to mitigate the risks for credit unions, Luke Martone, CUNA’s senior director of advocacy and counsel.
“We believe certain ‘bad’ check offenses…generally are low-risk and should be treated as de minimis,” he added.
Source: CU Times
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Weekly Regulatory Advocacy Report
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The Weekly Advocacy Report provides links to information about a number of recent League, CUNA and NCUA regulatory and advocacy activities.
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Upcoming Education Sessions
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The League has several education sessions coming up. Several focus on compliance issues. They are listed in calendar format on the League website.
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League Consulting Department Staff
(800) 285-5300
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There's more available from InfoSight
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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.
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