Newsroom
CUs encouraged to offer insights on beneficial ownership reporting, BSA risk management guidance
In a new post on NAFCU's Compliance, Risk, & BSA Network, NAFCU's Kaley Schafer seeks feedback from credit unions on two rulemaking efforts regarding the Bank Secrecy Act (BSA) that are currently underway: the Financial Crimes Enforcement Network’s (FinCEN) advance notice of proposed rulemaking (ANPR) related to the implementation of the beneficial ownership information reporting provisions, and an interagency request for information (RFI) on risk management guidance as it relates to compliance with BSA/anti-money laundering (AML) requirements.
In the post, Schafer, NAFCU’s senior regulatory affairs counsel, highlights the ANPR from FinCEN soliciting feedback on the best approach to implement provision in the Corporate Transparency Act (CTA). The provision requires a non-public, secure database where certain reporting companies must disclose their beneficial owner information to be created. The CTA, enacted in January, was included in the fiscal year 2021 National Defense Authorization Act (NDAA).
Credit unions can provide feedback and insights on this topic by emailing Schafer at kschafer@nafcu.org; comments are due to NAFCU April 20. For more information on the ANPR, NAFCU previously sent members a Regulatory Alert breaking down what credit unions need to know.
In addition, Schafer also encourages credit unions to submit feedback on the RFI issued by the federal regulators – including both FinCEN and the NCUA – seeking input on the Interagency Supervisory Guidance on Model Risk Management and how it supports credit unions’ BSA and Office of Foreign Assets Control (OFAC) compliance.
NAFCU Thursday sent members a new Regulatory Alert to outline the RFI and provide background information on current BSA and OFAC requirements. In addition, NAFCU noted that the RFI will enhance the agencies’ understanding of credit union practices in this area and will determine whether additional explanation or clarification may increase transparency, effectiveness, or efficiency.
Credit unions can provide insights on the RFI by reaching out to NAFCU Regulatory Affairs Counsel Aminah Moore at amoore@nafcu.org. Comments are due to NAFCU May 27.
View the Regulatory Alert for more information and subscribe to receive Regulatory Alerts in your inbox.