October Recap Available

October’s Recap is now available here. Passwords to access the blog posts, and blog posts are only for CSG owners and retained clients. These should not be shared outside of the organization. Blog posts generally contain only a summary of any requirements, and do not represent all potential impact on the organization. For further details on any blog post, contact … Read More

Technical Amendments to the Beneficial Ownership Rule

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 gets transferred over.  At this … Read More

August Legislative Recap

August’s Legislative Recap is now available.  Let us know if you have any questions. Passwords to access the blog posts, and blog posts are only for CSG owners and retained clients. These should not be shared outside of the organization. Blog posts generally contain only a summary of any requirements, and do not represent all potential impact on the organization. … Read More

Operation Chokepoint is Officially Choked Out

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“All of the Department’s bank investigations conducted as part of Operation Chokepoint are not over, the initiative is no longer in effect, and it will not be undertaken again.”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 to curtail legal but disfavored … Read More

June 2017 Regulatory Recap

June’s recap is available at:  https://complianceservicesgroup.com/wp-content/uploads/2017/07/LEGISLATIVE-UPDATE-June-2017.docx. Passwords to access the blog posts, and blog posts are only for NWCG owners and retained clients. These should not be shared outside of the credit union. Blog posts generally contain only a summary of any requirements, and do not represent all potential impact on the credit unions. For further details on any blog … Read More

April Legislative Recap

April’s legislative recap is now available. Please let us know if you have any questions.  

WA Bulletin B-17-04 Exam Focus for Consumer Protection Compliance

On February 23, the DCU released Bulletin B-17-04, Exam Focus for Consumer Protection Compliance During 2017 through 2020.  The Bulletin details the compliance exam focus for 2017 – 2020. Exam Focus for Consumer Protection Compliance During 2017 through 2020 In March 2017, the Division of Credit Unions (Division) will complete its first cycle of enhanced consumer protection compliance exams for … Read More

WA House Bill 1209 – Public Depositories

The bill revises the definition of Financial Institution to include credit unions for public depositories in regards to RCW 39.58 Public Funds – Deposits and Investments – Public Depositories There is currently not a companion bill in the Senate. Sec. 3. RCW 39.58.108 and 2016 c 152 s 4 are each amended to read as follows: (1) Except as provided … Read More

Change to Secretary of State Corporate Formation Documents

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 the Office of Secretary of … Read More

DCU Bulletin B-16-17 Guidance on Money Service Businesses

On September 30, the DCU released Bulletin B-16-17, which provides Guidance on Money Service Businesses (MSBs). Operation Choke Point, and additional pushing from regulators, urged financial institutions to avoid offering services to specific businesses identified as high risk – such as money service businesses.  In late 2014, the DOJ and FDIC determined that they should not be doing this, and … Read More