Starting May 11, 2018, credit unions and other financial institutions are required to have new procedures in place when it comes to customer due diligence, primarily involving “beneficial owners” and “legal entity” members. CUNA’s compliance staff addressed a key question in a recent CompBlog entry: Do the new requirements mean credit unions have to change Bank Secrecy Act (BSA) procedures to update member information regularly?
The answer is no, the rule does not require credit unions to update member information on a continuous or periodic basis. The updating requirement is event-driven and only occurs as a result of detecting unusual activity through normal monitoring.
The new procedures required by May 11, 2018, are:
The rule also provides two new definitions:
For more details, see the CompBlog entry, as well as the CompNotes final rule analysis.