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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.
CONFERENCE CALL: CHANGES TO REG Z
updated 05/23/16 03:02 PM
OT Rules, Deposit Recon. Practices
Credit union professionals can join a conference call briefing on May 25 by the Consumer Financial Protection Bureau (CFPB) regarding changes to Regulation Z implementing the Helping Expand Lending Practices in Rural Communities Act (HELP Rural Communities Act) contained in the Fixing America’s Surface Transportation Act (Public Law 114-94).
FINCEN PUBLISHES FINAL CDD RULES
updated 05/17/16 08:02 AM
TILA-RESPA Citations Resources
The Financial Crimes Enforcement Network (FinCEN) has issued final rules under the Bank Secrecy Act to clarify and strengthen customer due diligence requirements for banks and credit unions, brokers or dealers in securities, mutual funds, and futures commission merchants.