Deadlines are approaching for NAFCU members to provide the association their views on three proposed rules from NCUA, CFPB and the Financial Crimes Enforcement Network.
NAFCU is preparing a comment letter in response to FinCEN's proposal to amend its existing rules on customer due diligence. The proposal would add a new regulatory requirement for financial institutions to identify beneficial owners of legal entity customers; this would be in addition to other identity verification measures already mandated. Comments are due to NAFCU Sept. 8 and to FinCEN Oct. 3.
The next Regulatory Alert deadline is for a comment letter in response to NCUA's fixed-assets proposal. The proposal would remove the requirement that federal credit unions get waivers from NCUA to exceed the 5 percent limit on investments in fixed assets; in its place would be a requirement for a credit union to implement a fixed asset management, or FAM, program in order to exceed the 5 percent limit on investments in fixed assets. Comments are due to NAFCU Sept. 12 and to NCUA Oct. 10.
Finally, NAFCU is preparing a comment letter in response to CFPB's proposal to amend Home Mortgage Disclosure Act reporting requirements. The proposal would, among other things, expand the data credit unions are required to collect and report under Regulation C. The proposal would also expand the scope of reportable transactions to include all closed-end loans, open-end lines of credit, and reverse mortgages secured by dwellings, regardless of the purpose of the loan or line of credit. Under this proposed expansion, it would be mandatory to report Home Equity Lines of Credits (HELOCs). Comments are due to NAFCU Sept. 17 and to CFPB Oct. 29.