FinCEN's CDD rule FAQs covered in new BSA Blast
NAFCU's quarterly BSA Blast e-newsletter, released to members yesterday, provides detailed explanations to some of the questions NAFCU has received related to the Financial Crimes Enforcement Network's (FinCEN) customer due diligence (CDD) rule, which has a mandatory compliance deadline of May 11.
The article, written by NAFCU Regulatory Compliance Counsel Stephanie Lyon, includes detailed responses to five questions:
- whether the CDD rule requires credit unions to collect signatures from legal entity members when they open an account;
- if a credit union should identify the owners of a business or the business itself when documenting the beneficial owner, if the business owns 25 percent of a legal entity;
- whether the trustor or the trustee of a trust that owns a legal entity should be identified in order to meet the beneficial ownership requirement;
- what is a qualifying event that would require credit unions to gather beneficial owner information on existing members; and
- if credit unions need to revise compliance signage for the USA Patriot Act.
Lyon also details other requirements of the CDD rule and provides additional resources – including FinCEN's first and second sets of interpretive guidance – to help credit unions meet the compliance deadline.
A separate article in the e-newsletter, by NAFCU Regulatory Paralegal Shari Pogach, details two recent enforcement actions taken by FinCEN and federal banking regulators. The actions included forfeitures and penalties totaling the highest ever annual total for federal authorities for Bank Secrecy Act and anti-money laundering (BSA/AML) violations in any prior years.
This issue of the BSA Blast also includes a forum with questions and answers about filing a suspicious activity report (SAR) when a validated identity theft is involved and whether credit unions need to keep copies of identification for new members opening an account.
A BSA quiz is also included in this quarter's e-newsletter, which focuses on the CDD rule.
Frequently Asked Questions
Business Lending BSA Examination & Enforcement
Add to Calendar 2020-02-04 14:00:00 2020-02-04 14:00:00 Challenges Your CU Will Face When Leasing or Buying a Branch Fixed assets are often one of the largest items in a credit union's budget. Branches or headquarters buildings are very costly, and Board of Directors and Management should use caution when spending member’s money. 2020 should be the year of the tenant and credit unions will have the opportunity to negotiate some amazing lease deals or renew their existing lease(s) and take advantage of the savings. Acquiring an existing building or branch will be a challenge, but this webinar will provide best practices on how to navigate the process. During this webinar, we’ll also highlight many of the options that credit unions have for acquiring a new building as well as walk through comprehensive checklists for leasing and purchasing. Several examples of how credit unions have succeeded or failed with acquiring new buildings will also be addressed. Key Takeaways Discuss lease issues and alternatives such as renew, recast, renovate and relocate Review comprehensive checklists for due diligence, purchase, and closing Learn more about decision matrix for new premises as well as current premises Walk through lists of regulatory issues and legal aspects of fixed assets Analyze case study examples Purchase Now$295 Members | $395 Nonmembers (Additional $50 for CD)One registration gives your entire credit union access to the on-demand recording until February 4, 2021.Already registered? Go to the Online Training Center to view live. Who Should Attend? Presidents and Chief Executive Officers Chief Operating Officers Chief Financial Officers Facilities Managers Internal Auditors Board of Directors and Supervisory Committee Credit Union staff attorneys Education Credits NCVEs will receive 1.5 CEUs for participating in this webinar. CPA credit information is below; recommended 1.5 CPE credits. CPA Certification Credit Information Reviewer: Josie Collins, Education Manager, NAFCU Learning Objectives: Discuss lease issues and alternatives such as renew, recast, renovate and relocate. Review comprehensive checklists for due diligence, purchase, and closing. Learn more about decision matrix for new premises as well as current premises. Walk through lists of regulatory issues and legal aspects of fixed assets. Analyze case study examples. Program Level: Basic Prerequisites Needed: None Advance Preparation Needed: None Delivery Method: Group Internet-Based Recommended CPE Credits: 1.5 credits Recommended Field of Study: Management Services - Technical National Association of Federal Credit Unions (NAFCU) is registered with the National Association of State Boards of Accountancy (NASBA) as a sponsor of continuing professional education on the National Registry of CPE Sponsors. Learn more. About Our Webinars Our webinars are streamed live from NAFCU headquarters near Washington, D.C. Your audio/video feed of the presenters includes presentation slides and downloadable handouts. You can easily submit your questions to the presenters at any time during the live broadcast, with no dialing over the phone! The audio and video stream directly through your computer. Web NAFCU email@example.com America/New_York public
Credits: NCVE, CPE
Get daily updates.
Subscribe to NAFCU today.