CUs: How would BSA recordkeeping, travel rule reg changes affect operations?
NAFCU sent members a Regulatory Alert Tuesday detailing the Financial Crimes Enforcement Network's (FinCEN) advanced notice of proposed rulemaking (ANPR) to amend the Bank Secrecy Act's (BSA) recordkeeping and travel rule regulations. NAFCU encourages credit unions to offer feedback on the proposed rule to help inform the association's recommendations to FinCEN.
The ANPR was proposed last month in coordination with the Federal Reserve Board and does not impose any new requirements to retain additional or new information under the recordkeeping and travel rules, other than those resulting from the change to the applicable thresholds.
In the Regulatory Alert, NAFCU highlights the changes that are made by the ANPR and explains how they may impact credit unions, including:
- a reduction of the recordkeeping and travel rule threshold from $3,000 to $250 for funds transfers and transmittals of funds that begin or end outside the U.S.; and
- a definition for the meaning of “money” in the recordkeeping and travel rules to apply to domestic and cross-border transaction involving convertible virtual currency.
In addition, NAFCU poses several questions for credit unions to consider when providing feedback on this topic. Comments on the proposed rule are due to NAFCU Nov. 24; comments are due to FinCEN Nov. 27.
Add to Calendar 2020-12-01 09:00:00 2020-12-01 09:00:00 Beyond the Pandemic Risk Series [Part 1]: Pandemic-Related Lending Portfolio Risks Listen On: Key Takeaways: [08:05] The most critical data that you can get your hands on would be any data that would provide you early indicators that there is going to be a delinquency issue. [10:35] One non-negotiable is that credit unions have a monitoring program that allows them to understand your risk exposure at any point in time. [13:57] Right now we can’t under-score social media; because we all interact virtually, there is a lot of good analytic and trending data that can be provided via social media. As long as you are doing that in a compliant and appropriate manner. Web NAFCU firstname.lastname@example.org America/New_York public
Get daily updates.
Subscribe to NAFCU today.