CDD: One Year Later | Survey Request

It's officially been one year since the CDD rule went into affect. Have you had an exam since then? What aspects of CDD and beneficial ownership, if any, did the examiner focus on? 

We're doing a short survey on the impact CDD is having on recent exams and would appreciate if you could take a few minutes to fill it out. We're happy to share the results if you participate. 

Thank you! 


    How the Government Shutdown is Affecting Regulatory Agencies

    Good afternoon, Bankers! Today's topic is the current government shutdown. This post originally appeared on the Ncontracts blog.

    How the Government Shutdown is Affecting Regulatory Agencies

    The partial government shutdown has furloughed workers at the national parks, the Smithsonian museums, the IRS, courts, and other federal institutions, but enforcement actions from federal banking agencies continue...

    READ THE FULL PDF: Download the attached PDF

      Non-member deposits for Low Icome CUs (LICU)

      Manager at a credit_union ($8.1BUSA)

      How do LICUs accept non-member deposits? Do they scan the non-member for OFAC? Do they KYC the non-member? Do they CIP the non-member? Does each non-member have an account number? Where are the funds held and how? Does Reg CC apply? I am struggling to find detailed information as to how LICUs manage non-member deposits. Any information would be greatly appreciated.

        New Regulatory Guidance About Cybersecurity Insurance

        Hello, Bankers! Today we are discussing cybersecurity insurance. This post originally appeared on the Ncontracts blog.

        New Regulatory Guidance About Cybersecurity Insurance

        Does your institution need cybersecurity insurance? Is it required? If utilized, are there rules? Cybersecurity insurance can protect against financial loss in the event of a cyber incident, but there are many intricate details...

        READ THE FULL ARTICLE: Download the attached PDF

          Free Webinar - How to Determine Your Critical Vendors

          Person at a Company (USA)

          Good morning, bankers! You're invited to join us for a free webinar on November, 16 where you can learn how to determine your critical vendors and how to make sure they don't negatively affect your FI's risk exposure. Can't watch live? Just register and you'll get the recorded version of the webinar. Register Here.

          Determining Critical Vendors

          What makes a critical vendor different from other vendors? The importance of properly determining your critical vendors is a key factor in your vendor management program. It maps out how you proceed in the vendor management process, with due diligence, monitoring and annual reviews. Knowing what questions to ask is at the forefront. Likewise, identifying who is a critical vendor, how many different types of vendors you should have and the criteria to determine the criticality of vendors is paramount to a successful vendor management program. This webinar will discuss:

          • How to determine inherent risk and vendor classifications
          • Considerations when risk rating your vendors, from NPPI, GLBA
          • Differences in the guidance by federal regulators including OCC, FRB, FDIC, and NCUA
          • What ‘critical vendor’ looks like in a post-Equifax breach realm

          Join us as we address critical vendors and the role increased vendor risk plays in the financial institution.

            Blog: Vendor Management - What the NCUA Really Wants

            Person at a Company (USA)

            This is part 3 of a 5-part blog series where we discuss what the agencies look for regarding vendor management.

            This post was originally published on May 2, 2017 at the Ncontracts blog.

            Today we are looking at the NCUA’s approach to vendor management, to better understand what the agency really wants from FIs.

            The NCUA outlines its expectations in Supervisory Letter No.: 07-01, Evaluating Third Party Relationships. Its guidance is based on three key concepts:

            1. Risk assessment and planning
            2. Due diligence
            3. Risk measurement, monitoring and control...

            Risk assessment should begin by looking within. A credit union should...

            READ THE FULLL ARTICLE: Download the attached PDF

              Loan Purchase Policy

              COO at a credit_union ($223MUSA)

              Hi - I was wondering if anyone had a sample of a loan purchase policy? We are looking to buy a block of loans from another credit union.

                General BSA/AML Requirements by Financial Institution Type - TRUPOINT Partners

                This one-page checklist outlines key BSA/AML requirements for different types of Financial Institutions, including: the four pillars of BSA/AML compliance, detailed internal controls, and additional elements. While it's not all-inclusive, this high-level list will allow you to evaluate your BSA/AML program for some of the primary elements the examiners will assess.

                It covers Banks, Credit Unions, Alternative Payment Providers, Mortgage companies (RMLOs) and Housing for Government-Sponsored Enterprises (HGSEs).

                  Fair Lending Compliance Checklist for Credit Unions - TRUPOINT Partners

                  Credit Unions face scrutiny from the NCUA, and the focus is increasingly on Fair Lending compliance.

                  This free checklist will show some areas that an exam will focus on, as well as key things to consider as you evaluate your Fair Lending compliance management program. Get it today!

                    Loan Incentive Policy

                    Manager at a credit_union ($1.7BUSA)

                    I'm not certain about other regulators but NCUA regulations require a federal credit union to have a Board approved loan incentive policy before embarking on a loan incentive program focused on lending employees. Does anyone have such a policy they would be willing to share? Thanks!

                      Credit Card Application Compliance - Via phone and in person signature

                      Person at a credit_union ($842MUSA)

                      Is it necessary to obtain the customer's signature at the time of application (existing customer)? When taking an application over the phone, other than the basic Reg Z items, is it required to disclose additional information? Does anyone have a sample of a script that may include these disclosures? Your assistance is much appreciated! Great weekend.