A resource for credit unions in CA & NV, providing credit union financial and economic trend analysis, brought to you by your Leagues in partnership with CUNA & Affiliates.
Answers to your crucial questions can be less than one business day away. Post your question here, and a talented compliance professional will get back to you quickly! Or if you prefer, call the PolicyWorks compliance hotline to speak directly with our knowledgeable consultants.
Compliance Hotline: (844) 731-6072
Continue for Ask PolicyWorks
DBO licensees included in the survey were sent an email notification to their DBO-designated emails, with additional details and information on how to access the survey.
The purpose of the survey is for DBO to maintain complete, accurate, and up-to-date information on licensees’ real estate loan portfolios to determine risks and assess the impacts of proposed regulatory or statutory changes at the federal and state levels. The survey collects 2013 data on residential mortgage loans secured by one to four unit family residential properties, including loans held in portfolio, loans held for sale, finalized foreclosures, completed short sales, modifications, and serviced loans.
Credit unions, banks, residential mortgage lenders, and finance lenders must complete the 2013 survey as a special report, pursuant to California Financial Code sections 455, 50307, and 22159.5.
For questions or more information, please email email@example.com.
Caution Urged Regarding Marijuana Businesses
New federal guidelines allow credit unions and others to provide financial services to marijuana dispensaries. However, this newfound leniency does not come without compliance burdens.
Colorado and Washington recently approved the legal sale of the drug from state-regulated dispensaries. The U.S. Treasury, Financial Crimes Enforcement Network (FinCEN), and U.S. Deputy Attorney General James Cole have all commented on the issues in recent weeks, telling financial institutions they may accept accounts from legal dispensaries.
However, the Credit Union National Association said in its CompBlog: “Until Congress changes the federal law so that marijuana-related businesses are no longer illegal at the federal level, credit unions may be taking a great risk providing financial services to these businesses.”
The compliance burdens could also be stifling for those deciding to take on dispensary accounts.
Financial institutions that work with these businesses should be aware of three new types of Suspicious Activity Reports ("Marijuana Limited" SAR, "Marijuana Priority" SAR, and "Marijuana Termination" SAR), as well as seven specific customer due diligence requirements, such as verifying with the state whether the business is duly licensed and registered.
Further, credit unions that work with dispensaries may need to determine whether or not marijuana from a given dispensary is:
"Not only does this compliance burden appear insurmountable, but also overreaching," CUNA said.
MLA DATABASE FEB. 15 DEADLINE
updated 02/09/16 08:00 AM
Plus, CUSO Registry Webinar
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 firstname.lastname@example.org.
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.