July 14, 2022

New on the Compliance Blog: Customer types, CFPB AO on FCRA and permissible purpose

compianceAs credit unions work to meet the needs of more than 131 million Americans, NAFCU's award-winning regulatory compliance team continues to keep credit unions informed with new posts on the Compliance Blog, published every Monday and Wednesday.

Here's a roundup of what's new this week:

Risky Business: Every Customer is Different: Senior Regulatory Compliance Counsel Nick St. John examines how certain professions or businesses, such as marijuana related businesses (MRBs), private ATM owners, politically exposed persons, nonprofit entities, and more, have been identified by regulators as potentially requiring more in-depth Bank Secrecy Act (BSA) compliance processes. This has caused some risk-averse credit unions to avoid doing business with said members – but federal financial regulators have recently pushed to encourage credit unions to welcome these customers with more open arms so long as BSA risks can be mitigated.

CFPB Issues Advisory Opinion on FCRA and Permissible Purpose: In Wednesday’s blog, Regulatory Compliance Counsel Keith Schostag shares an overview of the CFPB’s recently published advisory opinion on “Fair Credit Reporting; Permissible Purposes for Furnishing, Using, and Obtaining Consumer Reports.” Schostag highlights that although much of the focus of the advisory opinion is on credit reporting agencies (CRAs), it also discusses requirements for entities that obtain and use credit reports, reminding users that they must have a permissible purpose to obtain and use a consumer report.

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