One of the benefits of your credit union's League membership is access to InfoSight--a valuable online compliance resource. This newsletter contains some timely highlights, and access to InfoSight is a benefit of League affiliation, so it is password-protected. If you have a specific compliance issue or concern, contact our Consulting Department at (800) 285-5300. Replies to this email will be directed to SVP, League Services & Regulatory Analysis Joe Guilfoy .
InfoSight Highlight
Content Update
In response to a request from an InfoSight user, the Security Channel was recently updated with a new topic:  Active Shooter . Please review this serious topic to ensure the safety of your credit union staff and members.
Compliance Videos
Compliance Connection Video
In this video , League InfoSight CEO Glory LeDu talks about the highlights from the 4 th Quarter of 2018 and the 1 st Quarter of 2019.

When S.2155, the Economic Growth, Regulatory Relief, and Consumer Protection Act, passed in 2018 there was a lot to understand! Glory LeDu, League InfoSight CEO, provides Part 1 in this short video to break it down for you.

Just a reminder that Compliance videos since 2016 can be found on YouTube at the Compliance Connection channel , where they are generally updated quarterly.
Compliance News
Bureau releases report on servicemember complaints
The CFPB has posted a  Bureau Blog entry  announcing the release of the  sixth Annual Report  from the Bureau's Office of Servicemember Affairs (OSA) highlighting issues and emerging trends facing servicemembers, veterans, and military families. The annual review allows the CFPB to highlight and address critical issues and emerging trends facing the military community and informs the Bureau’s efforts to protect military consumers.

The OSA provides service to the military community by highlighting issues like abuses of the military allotment system, aggressive marketing of refinance offers to veteran homeowners, and full explanations of servicemembers’ rights under the Servicemember Civil Relief Act (SCRA). This year's Annual Report describes emerging servicemember issues in the financial marketplace such as:

  • Medical, telecommunications and VA debts on servicemembers’ credit reports
  • Student loan servicing obstacles
  • Automobile add-on products in the car buying process
 
Source: CFPB
Tax Season Has Begun – Prepare for Direct Deposits of Refunds
The IRS has shared the following reminders to taxpayers in regard to direct deposited tax refunds: 

  • Refunds can be split into as many as three separate accounts. For example, a checking, a savings, and a retirement account.
  • Refunds should only be directly deposited into accounts that are in the taxpayer’s own name, their spouse's name, or both if it's a joint account.
  • Refunds should not be direct deposited into an account in a return preparer's name.
 
 
Source: IRS/CUNA Compliance Blog
Are your CDD Policies Ready for Your Next Exam?
Last August, NCUA issued  Supervisory Letter (SL No. 18-01 ) to address credit union's compliance with the new BSA Customer Due Diligence and Beneficial Ownership Rules. With this letter, NCUA stated that credit unions could expect that "field staff would not identify non-compliance as a significant BSA violation, as long as credit unions were making a good faith effort to comply with the new rules." Credit unions were to expect this reprieve through the end of 2018. 

Well, we are now into 2019, and NCUA has listed "in-depth reviews of BSA/AML policies and procedures and assessing compliance with the customer due diligence regulation" as one of the agency's supervisory priorities for this year.

As you prepare for your next exam, some items you should consider include :

  • Does your written BSA compliance program include Customer Due Diligence and Beneficial Ownership Identification and Verification?
  • Have you established an adequate Customer (member) Due Diligence (CDD) Program?
  • Does your CU have effective procedures for developing member risk profiles that identify the specific risks of individual members or categories of members? 
  • Are your risk-based CDD policies, procedures, and processes commensurate with your credit union's BSA/AML risk profile, with increased focus on higher risk members? 
  • Do your procedures include identifying members that may pose a higher risk for money laundering or terrorist financing and whether and/or when, on the basis of risk, it is appropriate to obtain and review additional member information?

Source: CUNA Compliance Blog
Weekly Regulatory Advocacy Report
The Weekly Advocacy Report provides links to information about a number of recent League, CUNA and NCUA regulatory and advocacy activities. 
   
Upcoming Education Sessions
The League has several education sessions coming up. Several focus on compliance issues. They are listed in calendar format on the League website.
   
League Consulting Department Staff
(800) 285-5300
Compliance Calendar
There's more available from InfoSight
InfoSight content is available from the League's website . Visit anytime to get sample policies, links to federal regulations and summaries of issues that are hot-topics at your credit union. 
 
Access to InfoSight is a benefit of League affiliation, so it is password-protected. If you don't have a password or if you have forgotten yours, click on the tan "Log In" button in upper right corner of the site; a box will open. Click on the blue wording to get your password.