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As credit unions work to meet members' needs during the coronavirus pandemic and resume normal operations, NAFCU's award-winning Regulatory Compliance Team will continue to keep credit unions informed with new posts on the Compliance Blog every Monday, Wednesday, and Friday.

Here’s a roundup of Compliance Blog posts from this week:

New Credit Union Members Are Coming: Following the NCUA's recent Letter to Credit Unions detailing application requirements under the recently finalized field of membership (FOM) rule, NAFCU Regulatory Compliance Counsel Loran Jackson breaks down how to meet the "well-defined local community" requirement. Jackson reminds credit unions that the narrative approach can also be used, and notes the NCUA's clarification "that credit unions looking to update their charters should be prepared to provide the NCUA with the business rationale used to define a CSA or Core-Based Statistical Area (CBSA) if the defined area does not include an area’s largest county or named city."

ICYMI: NCUA Online Examiner's Guide Includes COVID-19 Chapter: NAFCU Vice President of Regulatory Compliance Brandy Bruyere flags that the NCUA added a chapter to the online examiner's guide related to the coronavirus pandemic, which "provides more details on the items highlighted as additional exam priorities as well as a discussion on how NCUA will review credit unions’ operational risk in light of COVID-19." Bruyere dives into key chapter sections on credit union operations, the paycheck protection program, and small-dollar loans.

Open for the Holiday: Ahead of the Columbus Day federal holiday, NAFCU Regulatory Compliance Counsel Janice Ringler highlights operational considerations for certain transaction processing if a credit union remains open. Ringler explains ACH processing subject to NACHA rules, mailed or ATM deposited checks, and incoming wires. Previous compliance blogs have address holiday considerations for Regulation CC and Regulation Z requirements.

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