CFPB’s Crystal Ball

The CFPB published a fact sheet on the agencies nine priority goals, and its two-year plan to accomplish these.  They provide a little insight on what is coming up on the regulatory horizon.  Listed below are their focuses, and planned steps for the next two years to accomplish them. ARBITRATION The CFPB envisions a consumer financial marketplace where consumers have … Read More

No-Action Letters

The CFPB finalized a policy that aims to promote innovation in the financial services marketplace. Generally, the policy establishes a process for companies to apply for a “no-action letter” from the Bureau. The no-action letter essentially indicates that the Bureau has no present intention to recommend or initiate any enforcement or supervisory action with respect to the company’s product or … Read More

Cybersecurity Information Sharing Act of 2015

On December 18, 2015, Congress passed and President Obama signed into law the Cybersecurity Information Sharing Act of 2015, which is designed to increase cybersecurity information sharing between the private sector and the Federal Government. The Act provides various protections to non-federal entities that share cyber threat indicators or defensive measures with the Federal Government. DHS’s Automated Indicator Sharing (AIS) … Read More

More BSA on the way?

In January, the Government Accountability Office released a report, in response to Congress’ request, titled Internal Remittances – Money Laundering Risks and Views on Enhanced Customer Verification and Recordkeeping Requirements. This was initiated from a 2015 Senate bill, the Remittance Status Verification Act of 2015.  While the Act did not proceed further, it would have required remittance transfer providers (including credit unions) to, before … Read More

HMDA File Specifications

The CFPB has posted HMDA file specifications for 2017 and 2018. For data collected in 2016, credit unions should follow the FFIEC’s file specifications. For data collected in 2017 and data collected in or after 2018, credit unions should follow the CFPB’s file specifications. _  _  _ As a reminder, The NCUA released a Regulatory Alert reminding credit unions of … Read More

MSB Refresher

The NCUA released its February 2016 issue of the NCUA Report. The Report contains a good overview of the requirements for credit unions if they offer accounts to Money Service Businesses. While credit unions are allowed to provide accounts and services to MSBs, the credit unions must have proper controls in place to identify and manage the risks inherent with … Read More

In the legislature

Washington and Oregon’s legislature is back in session after the holidays, and both states have a couple bills that, if enacted, would have impact on credit unions. In Washington, Senate Bill 5635 would repeal Washington’s Power of Attorney Act and replace it with a modified Uniform Power of Attorney Act – which 18 states have currently adopted.  This bill is … Read More

CFPB Takes Steps to Improve Checking Account Access

Through a field hearing on checking account access, the release of an announcement and Compliance Bulletin 2016-01, the CFPB encourages financial institutions to provide lower-risk accounts to consumers that either do not want, or are unable to qualify for an account, that provides overdraft protection. The releases contain a number of items related to this topic. Lower-Risk Product Offering The … Read More

The IRS Wants Your Help

U.S. Treasury Asks Financial Institutions to Encourage Customers to Use Direct Deposit for Tax Refunds The Fiscal Service and the Internal Revenue Service (IRS) have been working collaboratively to increase direct deposit for the upcoming 2016 tax filing season. Together we have developed the key social media messages that we are asking you to use in order to encourage your … Read More

Proposed changes to CTR

FinCEN seeking input on proposed changes to improve the layout of the CTR form. FinCEN is proposing a number of technical changes to the CTR (or BCTR – Bank Secrecy Act Currency Transaction Report) to allow for alternative reporting models that have developed since the current CTR was created. The proposed changes include reports filed by a parent company on … Read More