Compliance Blog

NAFCU has updated its Book of Answers.   NAFCU members can access it here.  (Second link in research tools area.)  The Book of Answers is a growing compilation of questions and answers that appear in our monthly regulatory compliance newsletter. 

If you were a member, you'd see tons of groovy stuff like this:

Question: My credit union received a grand jury subpoena concerning a member. Must we file a suspicious activity report (SAR)?

Answer: Not necessarily. FinCEN indicates that the receipt of a grand jury subpoena means that a grand jury seeks information while investigating the subject of an investigation, and therefore the receipt of such a subpoena, by itself, does not mandate the filing of a SAR. The receipt, however, should trigger a risk assessment of the member’s account and a review of account activity. Should the review uncover suspicious activity, a credit union should submit a SAR pursuant to regulatory requirements and applicable dollar thresholds. See FinCEN’s SAR Activity Review, Trends Tips & Issues (Issue 10), pp. 42-43. The same logic will apply when a member’s account is the subject of any other type of subpoena, 314(a) request, or national security letter.
March 2007

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NCUA's monthly board meeting is today.  After 9 a.m., you can read the draft board items here.  From a compliance point of view, the NCUA is set to adopt a final rule regarding eligible obligations.