CompBlog Wrap-Up looks at customer due diligence, important dates

September 12, 2014

WASHINGTON (9/15/14)--The Credit Union National Association's CompBlog has published its monthly Wrap-Up, which contains the top compliance issues that came up over the month of August.

The U.S. Department of the Treasury's Financial Crimes Enforcement Network (FinCEN) has estimated its new customer due diligence proposal could result in an additional 20 minutes to open an account. CompBlog staff wonders if that is too much for credit unions.

The rule requires credit unions to establish written procedures to identify and verify owners of certain legal entity members. Individuals opening accounts must fill out a new certification form which is meant to help the credit union certify the information provided is correct.

Credit unions will be required to maintain the certification form and other identifying information for five years.

CUNA staff is collecting comments from credit unions about whether they agree with FinCEN's estimation that the new rule will add 20 minutes to account opening, and how any additional time will impact a credit union's business.

Other items included in the Wrap-Up include:

  • Consumer Financial Protection Bureau (CFPB) rules and guidance on international money transfers, mortgage servicing, overdrafts and virtual currencies;

  • The National Credit Union Administration's appraisals, cybersecurity, fixed assets and fraud prevention proposals, as well as a mention of new NCUA board member J. Mark McWatters;

  • Regulatory calls for action for the CFPB's disclosure of narrative complaint data (comments due by Sept. 22), the NCUA's fixed-assets proposal (comments due Oct. 10) and the CFPB's proposed regulation on the Home Mortgage Disclosure Act, Regulation C (comments due Oct. 29); and

  • Effective dates of the NCUA's voluntary liquidations final rule (July 28), the CFPB's remittance transfer regulation (late October), federal regulators' appraisals for higher priced mortgage loans (July 18, 2015) and the CFPB's "Know Before You Owe" disclosures (Aug. 1, 2015).

The wrap up also includes links to several question and answer sessions from CUNA compliance staff on Operation Choke Point, advertising, the Bank Secrecy Act, home equity lines of credit, the Internal Revenue Service, mortgage loans and mortgage servicing.

Use the resource link below to access the full Wrap-Up.

August CompBlog Wrap-Up