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

August Compliance Recap

August’s compliance recap, with a summary of regulatory issues that might impact the credit union, is available here.

CFPB Spring 2016 Rulemaking Agenda

The CFPB’s Spring 2016 Agenda has been published, and it looks like we may have a busy summer.  Compliance folks may want to get some sleep this weekend, because it may be your last chance.  Of the rules on the list, the following may have impact on credit unions. In the Prerule Stage: Business Lending Data (Regulation B) Section 1071 … Read More

Interagency Guidance Regarding Deposit Reconciliation Practices

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 full credits of their deposits … Read More

Elder Financial Exploitation Webinar

If it’s free, it’s me… On Wednesday, May 25 at 11:00, the CFPB will hold a webinar on how financial institutions can protect older consumers from financial exploitation.  The presentation will highlight a recent CFPB report, Recommendations and Report for Financial Institutions on Preventing and Responding to Elder Financial Exploitation.  We blogged about the report here:  https://complianceservicesgroup.com/cfpbs-advisory-report-financial-institutions-preventing-elder-financial-abuse/. Credit unions can … Read More

Washington Uniform Power of Attorney Act

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, 2017. Credit unions should: Review the new allowances and requirements for POAs created after January 1, 2017 Plan on using the new Certification form beginning … Read More

Beneficial Owner Verification Requirements

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 of a legal entity customer, … Read More

Oregon Marijuana Banking Bill – Updated

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, or manufacturing marijuana or marijuana-derived … 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