Proposed SAR Changes

FinCEN has published a notice of proposed changes to the SAR form.  The notice does not propose any new regulatory requirements or changes to the requirements related to suspicious activity reporting other than changes to the data fields provided in the SAR filings.  Most of the proposed changes would alter the “checklist” of violations in Part II, including the addition … Read More

Contaminated Currency

From the Federal Reserve: January 30, 2017 In response to customer feedback, the Federal Reserve updated its procedures for submitting deposits of contaminated currency. The updated procedures are available on the Contaminated Currency and Coin page of FRBservices.org. In addition, the FedCash® Services Contaminated Currency Notification Form (CASH-04) and Deposit Visual Reference Guide were updated to reflect the changes. Effective … Read More

Proposed WA House Bill 1053 – Addressing the Washington State Credit Union Act

There is a current bill in committee (HB 1053 / SB 5144) that, if enacted would: Modify credit union governance provisions related to supervisory committees and special membership meetings, and Modify low-income credit union designations and secondary accounts. In summary, the bill includes: Supervisory Committee The supervisory committee must: perform or arrange for additional audits as requested by the board … Read More

As a reminder – Washington Uniform Power of Attorney Act Effective 01/01/2017

Back in May we blogged about this (reprinted below), and since it goes into effect January 1, 2017, we thought we might refresh everyone’s memory… The Washington State Legislature passed Senate Bill 5635, which repeals the Washington State Power of Attorney Act and replaces it with a slightly modified Uniform Power of Attorney Act. The Act is effective January 1, … Read More

MAPCO Settlement

From cuna.org (11/21/16) A settlement has been proposed to resolve legal claims of financial institutions related to a May 2013 data breach.  Any credit union that issued payment cards that were compromised in the breach could get a payment from the class action settlement. In the proposed resolution agreement, involving lawsuits against MAPCO Express, Inc. and Delek US Holdings, Inc. … Read More

IRS Waiver of 60-Day Rollover Requirement

Effective August 24, the IRS changed its appeals process for people who miss the 60-day deadline to rollover funds from a qualified plan or IRA.  The appeals process allows people to provide a self-certification that meets the requirements. For the purpose of accepting and reporting a rollover contribution into a plan or IRA, a plan administrator (credit union) may rely … Read More

Prepaid Account Regulations

On October 5, the CFPB released its final rule for prepaid accounts under the Electronic Fund Transfer Act (Regulation E) and the Truth in Lending Act (Regulation Z). The rule, which is nearly 1700 pages, provides sweeping consumer protections that impact all aspects of the prepaid industry. The rule, which generally becomes effective on October 1, 2017, will require prepaid providers … Read More

FIN-2016-A005 Cyber-Events and Cyber-Related Crime Reporting

On October 25, 2016, FinCEN released FIN-2016-A005, Advisory to Financial Institutions on Cyber-Events and Cyber-Enabled Crime. It serves as a refresher of the credit union’s SAR filing obligations when encountering cyber-events. A financial institution is required to report a suspicious transaction conducted or attempted by, at, or through the institution that involves or aggregates to $5,000 or more in funds … Read More

Final Prepaid Account Rules Released

On October 4, the CFPB released its final rule for prepaid cards.  The rule will cover traditional prepaid cards, general-purpose reloadable cards, mobile wallets, person-to-person payment products, and other electronic prepaid accounts that can store funds.  Payroll cards, student financial aid disbursement cards, tax refund cards, and certain federal, state, and local government benefit cards such as those used to … Read More

NACHA Third-Party Sender Registration Requirements

Effective September 29, NACHA’s Third-Party Sender Registration Rule will go into effect, and require that originating depository financial institutions (ODFI) submit and maintain information on every third-party sender with which it maintains a relationship.  A third-party sender is a processing intermediary between a financial institution and an end-user of ACH payments.  The Rule will require ODFIs to provide information regarding … Read More