CUNA compliance experts remind credit unions that there are only 18 months left until a new Member Due Diligence rule goes into effect on May 11, 2018.
CUNA Senior Federal Compliance Counsel Colleen Kelly acknowledges in a recent blog post that it is a challenge for credit unions to jump on MDD compliance while the Military Lending Act, Home Mortgage Disclosure act and member business lending, and plenty of other compliance challenges are loomimg.
“But remember (the Financial Crimes Enforcement Network) extended the (MDD) compliance date for a reason. Use your time well. It’s never too early to determine what changes you will have to make to your policies, procedures and software systems,” she writes.
At a minimum, credit unions should be considering how they will: