Marijuana Related Business – WA Exam Update

The DFI released updated examination procedures for marijuana related businesses directed to DCU examination staff. Included in the procedures is an appendix that focuses on pricing of accounts for, and lending to, marijuana related business accounts.  It is an eye-opening read for credit unions considering loaning to these businesses. In addition to the updated examination procedures, the DFI has a … Read More

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

Federal Credit Union Fixed Assets Proposal

The NCUA proposed an amendment to the fixed-assets regulation that eliminates the requirement that a federal credit union must plan for, and eventually achieve full occupancy of acquired premises.  If passed, the credit union must partially occupy (at least 50% by the federal credit union or the federal credit union and a CUSO) within a reasonable period, but no later … Read More

Proposed Incentive-Based Compensation Arrangements

Section 956 of the Dodd-Frank Act requires the banking agencies (NCUA, FDIC, Federal Reserve System, Federal Housing Finance Agency, OCC, and the SEC) to jointly prescribe regulations or guidelines to prohibit incentive-based payment arrangements that the agencies determine to encourage inappropriate risks by providing excessive compensation or that could lead to material financial loss. Section 956 also requires that the … Read More

Quickies 4/13/16

NCUA posts report on serving the credit-invisible “Serving the Credit-Invisible,” a new report posted by the NCUA, explains how credit unions can build loan programs based on sound underwriting, appropriate risk management, loan monitoring and staff training that can help them reach this underserved population. The report details how to evaluate a loan applicant who is “credit-invisible” and describes best … Read More

BSA Violations

FinCEN’s penalty assessment against Gibraltar Private Bank reads like a Stephen King novel for BSA compliance officers. The ongoing deficiencies and either the willful blindness or ignorance by Gibraltar caused me heartburn just reading the assessment report. Gilbraltar’s issues have been ongoing since at least 2010, when the OCC first warned Gibraltar of its BSA deficiencies. A Consent order was … Read More

DCU 2016 Exam Focus

The Division of Credit Unions has published Bulletin B-16-02, which establishes their exam focus for 2016. The bulletin lists four focus areas for 2016: Cybersecurity This goes hand-in-hand with NCUA’s focus of cybersecurity risks. The DCU hired Security Compliance Associates (SCA) to assist them in performing IT security examinations. The main differences that credit unions will see in the Division’s … Read More

CUSO Registration

NCUA’s CUSO Registry will be available for CUSOs to begin registering on February 1, 2016.  CUSOs must register between February 1 and March 31. Federally insured credit unions are required to enter into written agreements with any CUSOs they make loans to or invest in. Each agreement must be signed before a credit union invests in or lends to a … Read More

Target Data Breach Settlement Website

A Target Data Breach Settlement website has been released providing information for financial institution class members of the Target data breach litigation. The website includes settlement terms, frequently asked questions, claim instructions and an on-line claim application. CLAIMS MUST BE FILED ONLINE (OR POSTMARKED FOR MAIL) ON OR BEFORE MARCH 22, 2016. If the credit union has not previously released … Read More