Category Archive

Inflation adjustments for Regulation CC – Availability of Funds and Collection of Checks will be effective on July 1, 2025. These adjustments will be applicable for the next five years, at which time a new schedule may be implemented. The adjustments will require financial institutions to update their disclosures and systems to reflect the new amounts. The adjustments include: Minimum … Read More

In Letter to Credit Unions 25-CU-01, the NCUA outlined its supervisory priorities and updates to its 2025 examination program. The letter states that “there continued to be signs of financial stress on credit union balance sheets during 2024. Aggregate loan performance began to deteriorate in 2022, and the trend has continued through 2024. The overall loan delinquency rate is currently … Read More

We run into a lot of confusion over the use of the terms dividends and interest in credit union account advertising and disclosures. Federally chartered credit unions cannot offer interest-bearing deposit accounts, only dividend-bearing accounts. State chartered credit unions can offer dividend-bearing or interest-bearing accounts, and in some cases both, depending on state law and the credit union’s bylaws. So, … Read More

We get asked this question frequently, and it comes down to the definition of banks and financial institutions in the Financial Crimes Enforcement Network’s (FinCEN’s) Bank Secrecy Act requirements under Regulation X. Regulation X sets the groundwork for Bank Secrecy Act (BSA) requirements and applies to “financial institutions.” Financial institutions include among others, banks, brokers or dealers in securities, money … Read More

November’s Regulatory Recap is now available here. It includes new rules from the NCUA, CFPB, FTC and FinCEN, among other happenings during the month. Please be advised that CSG provides financial services compliance audit and consulting services to our clients.  The services that we provide include certain tasks that may be characterized as “law-related services” under Rule 5.7 of the Rules … Read More

October’s Regulatory Recap is now available here. It includes proposed rules on debit card interchange fees, personal financial data rights, and convertible virtual currency mixing, among other happenings during the month. Please be advised that CSG provides financial services compliance audit and consulting services to our clients.  The services that we provide include certain tasks that may be characterized as … Read More

The CFPB issued an Advisory Opinion regarding Section 1034(c) of the Dodd Frank Act, which generally prohibits large banks and credit unions from imposing unreasonable obstacles on customers for basic information about their own accounts. Large banks and credit unions under the CFPB’s regime must provide complete and accurate account information when requested by accountholders. The Advisory Opinion clarifies that … Read More

September’s Regulatory Recap is now available here. It includes updates to TILA thresholds, proposed regulatory capital rules, and guidance on representment fees, pig butchering, and artificial intelligence on Adverse Action Notices. Please be advised that CSG provides financial services compliance audit and consulting services to our clients.  The services that we provide include certain tasks that may be characterized as … Read More

August’s Regulatory Recap is now available here. It includes updates to ADA compliance, a FinCEN alert, and supervisory highlights. Please be advised that CSG provides financial services compliance audit and consulting services to our clients.  The services that we provide include certain tasks that may be characterized as “law-related services” under Rule 5.7 of the Rules of Professional Conduct governing lawyers.  Since … Read More

Beginning Friday, September 1, 2023, the NCUA’s new Cyber Incident Notification Requirements Rule goes into effect. All federally insured credit unions will need to notify the NCUA as soon as possible, and no later than 72 hours, after the credit union reasonably believes it has experienced a reportable cyber incident or received a notification from a third party regarding a … Read More