FinCEN released technical amendments to its Beneficial Ownership Rule, as part of its Customer Due Diligence requirements effective May 11, 2018. Part of the amendments update the Beneficial Owner Certification Form. We have updated our version, available here, for institutions to use. (Note, we have recently switched web hosts, and are experiencing bugs, while everything… Read More »
In an August 16, 2017, letter to the Judiciary Committee, the Department of Justice stated that “All of the Department’s bank investigations conducted as part of Operation Chokepoint are not over, the initiative is no longer in effect, and it will not be undertaken again.” Operation Chokepoint was the brainchild of the Department of Justice… Read More »
In case you missed it… As a result of a change in Washington’s Business Code (RCW 23.95), the DFI sent an e-mail to Washington State credit union CEOs regarding corporate formation documents filed with the Secretary of State’s office. The email was: Dear CEOs, New laws (RCW 23.95) will soon take effect with regard to… Read More »
On May 18th, the Banking Brotherhood (Federal Reserve System, CFPB, FDIC, NCUA and OCC) released guidance for institutions regarding deposit reconciliation practices. If you recall, last year the CFPB, OCC, and FDIC took action against Citizens Bank for failing to credit consumers the full amounts of their deposited funds. “Citizens Bank regularly denied customers the… Read More »
FinCEN released a Final Rule under the Bank Secrecy Act, which imposes specific requirements for financial institutions to identify and verify the identity of beneficial owners of legal entity customers when opening a new account. Beneficial owner – is either an individual who directly or indirectly owns 25 percent or more of the equity interest… Read More »
Updated: On April 4, 2016, Governor Brown signed the law, and it is now effective. House Bill 4094 was passed by both the House and Senate, and now awaits Governor Brown’s signature. This provides financial institutions with an exemption from Oregon State criminal law for providing financial services to legal marijuana related services – possessing, delivering,… Read More »
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… Read More »
The Treasury has issued an updated version of The Guide to Cashing Savings Bonds. The Guide in provided in an interactive PDF format and covers authenticity and eligibility, customer entitlement, identify verification, required identification documents and payment. The Guide replaces all past versions of this document.
The NCUA’s rule codifies the insurance coverage pursuant to the Insurance Parity Act for IOLTAs and other accounts that satisfy the definition of “other similar escrow accounts.” The Credit Union Share Insurance Fund Parity Act was passed in December 2014, and provides coverage to IOLTA and “other similar escrow accounts.” Credit unions raised many questions… Read More »
The Rule is intended to improve ACH Network quality by reducing the incidence of ACH debits that are returned as unauthorized. Under this Rule, an ODFI will pay a fee to the RDFI for each ACH debit that is returned as unauthorized (return reason codes R05 reserved, R07 authorization revoked by customer, R10 customer advises… Read More »
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