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Federal Regulators, FinCEN Issue CIP Exemption Order
Friday, October 5, 2018 7:00 AM

The National Credit Union Administration, along with FinCEN, Federal Reserve Board, FDIC, and OCC, has issued an exemption for the Customer Identification Program (CIP) requirements. See Section 748.2 of the NCUA’s Rules and Regulations for certain property and casualty finance contracts provided by credit unions to small businesses.

Credit unions must still comply with all other regulatory requirements of the Bank Secrecy Act, including the requirement to file suspicious activity reports as applicable.

In their joint order, the agencies determined that the activity does not pose a risk to the U.S. anti-money laundering regime or otherwise pose a safety and soundness threat to the federally insured credit union system.

The joint order also grants an exemption from CIP requirements for premium finance loans. The exempted transactions are extended by banks, which by definition includes credit unions subject to the jurisdiction of the NCUA, and their subsidiaries to commercial customers to facilitate purchases of property and casualty insurance policies (premium finance loans or premium finance lending).

Source: InfoSight Compliance

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