Compliance Watch

Question: We have a member that designated his account as payable on death, with four persons to receive proceeds of the account upon his death. That member has since passed, but only two of the four beneficiaries outlived the member. Since that time, we’ve had the surviving family members of the deceased beneficiaries ask for their share of the account funds. Can we pay a share to them, or can we only pay to the surviving beneficiaries?

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FinCEN has announced it will convene a FinCEN Exchange in Aug. 2021 with representatives from financial institutions, other key industry stakeholders, and federal government agencies to discuss ongoing concerns regarding ransomware, as well as efforts by the public and private sectors.

The Federal Housing Finance Agency has announced that Fannie Mae and Freddie Mac will eliminate their controversial Adverse Market Refinance Fee for loan deliveries effective Aug. 1, 2021.

The Small Business Administration has issued Procedural Notice 5000-812316, "PPP Guaranty Purchases, Charge-Offs, and Lender Servicing Responsibilities," on how lenders can apply to have SBA purchase and charge off Paycheck Protection Program loans for which the borrower has not applied for forgiveness or made payment on the loan.

The IRS and the Treasury recently announced that millions of American families have started receiving monthly Child Tax Credit payments as direct deposits began posting in bank accounts and checks arrived in mailboxes.

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The CFPB has released an Enforcement Compliance Bulletin reminding landlords, consumer reporting agencies (CRAs), and others of their critical obligations to accurately report rental and eviction information.

OFAC has posted Guidance on Filing the Annual Report of Blocked Property and emailed a reminder that holders of blocked property under OFAC regulations must provide OFAC a comprehensive list of all blocked property held as of June 30 of the current year by Sept. 30 of each year.

FinCEN recently issued a notice to U.S. financial institutions to inform them that the Financial Action Task Force (FATF), an intergovernmental body that establishes international standards to combat money laundering, counter the financing of terrorism, and combat weapons of mass destruction proliferation financing (AML/CFT/CPF), has updated its statements concerning jurisdictions with strategic AML/CFT/CPF deficiencies.