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Research & Compliance     

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Compliance

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When technical challenges or complex situations arise at your credit union, turn to the Leagues’ PolicyWorks. Our mission is to provide technical, compliance, operational, economic, and regulatory information in an understandable and easily accessible way.
     
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From the Editors of CU Weekly

UNCLAIMED PROPERTY NOTICE ISSUED
updated 02/03/14 12:40 PM
Aggregate Reporting Threshold Lowered
The California State Controller’s Office has issued a notice detailing important updates regarding the new Unclaimed Property Law—Assembly Bill 212 (AB 212)—effective July 1, 2014.

Click here to read the notice.

Under current law, a person holding funds or escheated property worth at least $50 is required to submit a report to the controller that includes the name and last known address of the owner of any property (except traveler’s checks and money orders). Items valued less than $50 require the nature and identifying number, or a description of any intangible property reported.

AB 212 lowers the aggregate reporting threshold of unclaimed property from $50 to $25. The bill also requires holders to include the name and last known address of the property owner—except traveler’s checks and money orders—if the property is valued at $25 or more.

The bill authorizes the holder to impose a service charge of up to $2 for notices on a deposit, account, shares, or other interest that is valued at more than $2 (lowered from $50).

For more information, view the Leagues' Technical Information and Procedures (TIPs) Bulletin 13-45.

In addition, the controller’s office has issued its winter newsletter, which includes articles on the following topics:

  • Changes to Unclaimed Property Law—Aggregate Reporting
  • Legislative Updates
  • Holder Alert: Letters from Investigators
  • Did You Discover Additional Property
  • Look for Holder Remit Reminder Letters
  • The State Controller's Office Performs Due Diligence

 
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MLA DATABASE FEB. 15 DEADLINE
updated 02/09/16 08:00 AM
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Credit unions seeking a safe harbor under the Department of Defense’s (DoD) Military Lending Act (MLA) final rule will have two new options come Oct. 3, 2016: 1) A credit union may verify a borrower’s status on the DoD’s database, or 2) a credit union may use a consumer report obtained from a nationwide consumer reporting agency to determine whether a borrower is a “covered borrower.” Credit unions interested in utilizing the first option have until Feb. 15, 2016 to notify the Defense Manpower Data Center (DMDC) of their intent. This may be done by emailing the MLA helpdesk at dodhra.dodc-mb.dmdc.mbx.mla@mail.mil.

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CA PRIVACY NOTICES STILL REQUIRED
updated 02/02/16 08:35 AM
Plus, Latest PolicyWorks Newsletter
The FAST Act made changes to federal annual privacy notice requirements. However, it did not change California privacy notification requirements, which are applicable to all financial institutions doing business in California. California state annual privacy notifications are still required, depending on what information is shared and with whom.

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