Compliance Watch

NACHA has posted a Rules Outreach news item to remind ACH ODFIs that R11 returns (authorized debit with error such as wrong date or amount) will become subject to the NACHA unauthorized entry fee beginning April 1, 2021.

Question: We received a check for deposit addressed to “Jane Doe Life Estate”. Jane Doe wishes to deposit the check into her personal account. Is that permitted? Answer: Yes. Checks are typically addressed this way when they come from mineral or oil rights in land.

Compliance touches every part of the credit union.

On Dec. 23, 2020, FinCEN published a notice of proposed rulemaking (NPRM) proposing requirements for banks and money services businesses (MSBs) related to certain transactions involving convertible virtual currency (CVC) or digital assets with legal tender status (LTDA).

The Office of Foreign Assets Control has announced an upgrade of its sanctions list search tool. The fuzzy logic has been made more resource efficient.

The SBA has added FAQs 54–56 to its Paycheck Protection Program (PPP) FAQs to clarify that the Financial Crimes Enforcement Network’s April 2020 PPP FAQs still apply to second-draw PPP loans.

The Financial Crimes Enforcement Network has again issued FAQs confirming identical FAQs issued by SBA in connection with the Paycheck Protection Program. The SBA recently re-issued its PPP FAQs, adding two interpreting application of FinCEN regulations to Second Round PPP loans.

The Consumer Financial Protection Bureau has posted an article on its blog announcing an updated 2021 list of consumer reporting companies.

As our members shift to more remote solutions, providing apps that allow our members to exercise financial choices is quickly becoming the prevailing way we do business.

Well-capitalized, federally insured credit unions could count subordinated debt as capital for risk-based net worth purposes under a new rule approved by the NCUA Board at its meeting in December.