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Comments for Regulatory Proposals Due in October
Wednesday, September 24, 2014 6:45 AM

Comments on proposals from the National Credit Union Administration, Consumer Financial Protection Bureau, and the U.S. Treasury's Financial Crimes Enforcement Network are due during the month of October.

Cornerstone credit unions are urged to craft and send their comment letters as soon as possible. The proposals and deadlines are:

FinCEN: Customer Due Diligence

  • The proposal would amend Bank Secrecy Act regulations by strengthening customer due diligence obligations for financial institutions to identify and verify beneficial owners of legal entity customers.
  • Comments are due to FinCEN by Oct. 3.

NCUA:  Fixed Assets

  • The proposal would remove the waiver requirement for federal credit unions to exceed the 5% aggregate limit on investment in fixed assets.
  • The proposal would allow credit unions to exceed the 5% limit if it implements a fixed-assets management program.
  • Comments are due to NCUA by Oct. 10.

CFPB:  Home Mortgage Disclosure Act (HMDA) Regulation C

  • The proposal would revise tests for determining which institutions are covered under the HMDA. Covered entities, including credit unions that trigger Regulation C compliance, would be required to report HMDA data if they originate 25 covered loans other than open-end lines of credit and commercial lines of credit, in the previous calendar year.
  • Comments are due to CFPB by Oct. 29.

Please refer to Cornerstone's Regulatory Grid Summary or CUNA's Comment Calls page for more details about these proposals.

If you have questions, please contact Suzanne Yashewski, SVP Regulatory Compliance, at (512) 853-8516.