August 31, 2017
In This Issue
Lagniappe Listserv
Email the Lagniappe Listserv at  t o get input on compliance related issues, share best practices, or share policies, procedures and the latest in fraud awareness.   
Quick Links
ComplySight: FREE Recorded Webinars

Upcoming Educational Events
September 7

For a complete listing of educational opportunities available from LCUL and to register, visit the League website and click on "Education"
Compliance Toolkit
The BSA Officer's Toolkit contains tools to help manage your institution's BSA/AML program. It is designed to help you revamp and revitalize your BSA program before the examiners arrive.

Toolkit is provided by GetTechnical Inc. 

Did you know Photocopying a government ID is illegal?   

A lot of military members, their families and Defense Department employees don't know this, but photocopying any U.S. government identification is a violation of Title 18, US Code Part I, Chapter 33, Section 701.

The law reads, "Whoever manufactures, sells, or possesses any badge, identification card or other insignia of the design prescribed by the head of any department or agency of the United States for use by any officer or employee thereof, or any colorable imitation thereof, or photographs, prints, or in any other manner makes or executes any engraving, photograph, print, or impression in the likeness of any such badge, identification card, or other insignia, or any colorable imitation thereof, except as authorized under regulations made pursuant to law,  shall be fined under this title or imprisoned not more than six months, or both."

Commercial establishment can ask to  see your card to verify military affiliation or to provide government rates for services, but they can't photocopy it. So if they ask to do so, tell them no. Give them a state driver's license or other form of photo identification instead.

Photocopied cards might be used for counterfeiting purposes, with no real safeguards against it. Since criminals and terrorists value U.S. government IDs when they're trying to plan acts against the U.S. military, it's best to not give them that chance.

This law does NOT apply to medical establishments like hospitals and doctor's offices who are allowed to make a copy for filing insurance claims. It also doesn't apply to other government agencies that are using the copied ID to perform official government business.

Source: DoDLive
InfoSight Highlight: Interest Rate and FCUs 

The Federal Credit Union Act (the Act) permits Federal Credit Unions to make loans and extend lines of credit to members but prohibits FCUs from charging an annual percentage rate (APR), inclusive of all finance charges, above 15%. The Act, however, permits the NCUA Board (NCUA), after considering certain statutory criteria, to establish a higher interest rate ceiling in 18-month cycles. (The Federal Credit Union Act: Section 1757(5)(A)(vi)).

Current Increases
Since 1987, when the NCUA Board decreased the temporary ceiling from 21%, it has consistently acted to maintain a temporary ceiling of 18%. The current NCUA Board approved 18% ceiling remains in effect through March 10, 2017. (Per NCUA Rules and Regulations Part 701.21 (c)(7)(ii)).

Finance Charges
Finance charges that must be included in the determination of the interest rate are consistent with those defined in Regulation Z, Truth in Lending.

Penalty for Exceeding the Allowable Interest Rate
An FCU that knowingly charges or receives an interest rate that exceeds that allowed by law is subject to forfeiture of the entire amount on interest charged or received. Such action must be taken by the borrower or his legal representative within two years of the time the usurious collection was made.
Here's what you need to know about the new FFIEC HMDA Examiner Transaction Testing Guidelines   

The Federal Financial Institutions Examination Council (FFIEC) members announced new FFIEC Home Mortgage Disclosure Act (HMDA) Examiner Transaction Testing Guidelines (Guidelines) for all financial institutions that report HMDA data. The Guidelines will apply to the examination of HMDA data collected beginning in 2018 and reported beginning in 2019. 
The Guidelines will help ensure accurate data and address reporting burden concerns
When examining financial institutions, federal supervisory agencies with HMDA supervisory authority may verify the accuracy of HMDA data within a sample of reported transactions. If examiners find that the number of errors in the sample exceeds certain thresholds, an institution will be directed to correct and resubmit its HMDA data.   

CFPB launches new web form for regulatory inquiries    

The CFPB has announced a change to the process for submitting questions to the Bureau on regulations. The new web form  available here  replaces the email address (CFPB_RegInquiries previously used by the CFPB to accept questions and suggestions. 

As before, responses to questions submitted via the new web form are not official agency interpretations and shouldn't be relied on for compliance purposes. Submissions should receive a response within 10-15 days.

Source:  CUNA Removing Barriers Blog
Compliance Calendar

September, 2017

October, 2017

January, 2018

March, 2018

March 16th: Same-day ACH (NACHA) - Phase 3 of the implementation period for the rule


April, 2018

April 1st: Prepaid Accounts under the Electronic Fund Transfer Act/Regulation E and the Truth In Lending Act/Regulation Z (Date Extended)


May, 2018

May 11th: Customer Due Diligence - CDD (FinCEN) - Effective date