Today’s blog is going to focus on authorized users of credit cards. Specifically, we’ll go over whether credit unions are required to do any credit reporting on authorized users. Jumping right into it, under Regulation B, if the authorized user is a spouse, a credit union would be required to report on the authorized user …
Authorized Users on Credit Cards and Credit Reporting Read More »
Today’s blog is going to focus on Regulation E – specifically, provisional credit. First, when are credit unions required to provide provisional credit? Generally, under Regulation E, once a credit union has received a member’s notice of error, the credit union has 10 business days to complete its investigation in order to determine whether an …
We frequently receive compliance questions regarding various issues related to currency transaction reports (CTRs). However, this blog is going to address one of the scenarios I’ve been presented with recently. The question I received was regarding whether a withdrawal and a deposit can be included on the same CTR. So, what does the applicable guidance …
Recently I’ve received a couple questions regarding whether or not federal credit unions can use the terms “certificate of deposit” or “CD” when it comes to describing share certificates. So, what does NCUA require when it comes to the correct terminology? In order to set the stage, I first want to note that section 707.2(a) …
On April 18, 2024, the U.S. Department of Treasury’s Financial Crimes Enforcement Network (FinCEN) issued a Financial Trend Analysis that discusses Bank Secrecy Act (BSA) data regarding Elder Financial Exploitation (EFE). Per FinCEN, EFE is “the illegal or improper use of an older adult’s funds, property, or assets.” This blog will briefly discuss the patterns …
Happy Thursday, compliance friends! Today’s blog is going to discuss a topic that the Compliance Team at America’s Credit Unions gets quite a few questions about on a weekly basis. That topic? Record retention. Please note, this blog will not attempt to cover every possible record retention requirement. However, it will provide a brief overview …
I recently attended an NCUA webinar regarding the revised CDFI Certification Application and thought it may be helpful to provide a brief overview. Before we begin, let’s discuss what a CDFI actually is. CDFI stands for Community Development Financial Institutions and, according to this NCUA resource regarding the NCUA-CDFI Certification Initiative, “[t]he U. S. Treasury …
Community Development Financial Institutions (CDFIs) Read More »
Happy Tuesday, compliance friends! Over the past few months, I have received quite a few questions on what the requirements are for retaining periodic statements, so I thought it may be helpful to write a refresher blog surrounding these requirements. To start, NCUA provides general record retention guidelines that outline various record retention recommendations. This …
