Bureau Seeks Input on Streamlining Regs
CFPB wants public input on how to streamline the consumer regulations the agency inherited under the Dodd-Frank Act from various federal agencies. At press time, CFPB was in the process of republishing these regulations.
The “Notice and Request for Information” CFPB issued asks the public to identify provisions of the inherited regulations that the agency should make the “highest priority for updating, modifying, or eliminating because they’re outdated, unduly burdensome, or unnecessary.” Opportunities to streamline rules and facilitate compliance might include:
CFPB also wants input on how to make it easier for institutions, especially smaller ones, to comply with the regs. The initial comment period ends March 5, 2012. Commenters will have 30 additional days—until April 3, 2012—to respond to comments received during the initial period.
OFAC Creates Search Tool
The Office of Foreign Assets Control (OFAC) has a new online application that allows institutions to search the Specially Designated Nationals and Blocked Persons List (SDN List) across several criteria.
OFAC regulations require credit unions to block (freeze) property and/or reject transactions involving any country, entity, or individual appearing on the SDN List.
The new search tool is available at sdnsearch.ofac.treas.gov/.
Q How long must a credit union retain OFAC records?
A All Office of Foreign Assets Control (OFAC) records must be retained for five years. For items that are rejected in accordance with OFAC regulations, credit unions must maintain records for five years from the date of the transaction.
For blocked accounts, credit unions must maintain records for five years after the date that the account is unblocked. In addition, credit unions are required to maintain a full and accurate record of the blocked account for as long as the credit union is holding the blocked property.
Q What should a credit union do if it determines that it has filed incorrect information on a Suspicious Activity Report (SAR)?
A File a corrected report. When correcting an error on a previously filed SAR, mark box 1 (“Corrects prior report”) and follow the directions to make the necessary changes. Whenever a corrected report is filed, the credit union should explain the changes in the SAR narrative. The credit union may need to correct a clerical error, such as an incorrectly reported name or address. Or, it may discover previously undetected suspicious activity related to a previously filed SAR, in which case the date range, dollar amounts, summary characterization and narrative of the original SAR may need to be amended.
Visit CUNA’s compliance blog—“CompBlog”—at cuna.org. Email firstname.lastname@example.org with questions or ideas for blog posts, and keep the conversation going with your peers on COBWEB, CUNA’s compliance listserv.
Training Calendar 2012
Visit cuna.org/training-education for program and registration details