Compliance Update with Amy K
by Amy Kleinschmit
Chief Compliance Officer

Gramm-Leach-Bliley (Privacy Act) – Exam Focus

In our continuing highlight of 2020 NCUA Supervisory Priorities, next on the list is privacy. Examiners will continue to assess compliance with Gramm-Leach-Bliley (GLBA) to evaluate credit union protection of non-public personal information about consumers. The GLBA was enacted into law in 1999 and governs the privacy practices of a broad range of financial institutions.


Conveniently, we have a number of resources to assist credit unions in reviewing your privacy procedures. InfoSight has summaries, links to an online form builder that can be found hereCU PolicyPro has Model Policy 1615: Privacy, which can be found here.  


Remember, we are offering a FREE webinar on February 20 that will help you to better understand these dues-supported benefits of membership. I encourage you to sign up today for “Getting the most out of InfoSight and CU Policy Pro.” You can register for this webinar here.


TRID Survey

The Consumer Financial Protection Bureau (CFPB) is conducting a survey regarding the TILA-RESPA Integrated Disclosures (TRID). Participation in this survey is voluntary and responses will be confidential. Deadline to complete the survey is March 6, 2020.

These surveys will help the CFPB learn about the experiences of industry participants. Your participation in this survey will help the CFPB to better understand the effects of the TRID Rule and to more accurately estimate these effects.

The surveys can be found here.

These surveys are part of an overall effort to fulfill the CFPB’s statutory obligation to assess the TRID Rule’s effectiveness in meeting, among other things, its stated goals and the purposes and objectives in Title X of the Dodd-Frank Act. The assessment seeks to evaluate and quantify the costs and benefits of the Rule on institutions (e.g. loan officers, closing agents, and mortgage originators), consumers, and the overall mortgage market. The main purpose of the surveys is to collect qualitative and quantitative data on institutions’ implementation costs and ongoing costs and changes in consumers’ mortgage borrowing experiences associated with the TRID Rule.


The Financial Crimes Enforcement Network (FinCEN) has issued a Ruling that can be found here, on reporting of certain currency transactions for Sole Proprietorships and Legal Entities operating under a “Doing Business As” (“DBA”) name.

This ruling will become effective April 6, 2020. The effective date for BSA E-Filing batch filers is September 1, 2020. This ruling replaces and rescinds two rulings: FIN-2006-R003 and FIN-2008-R001.

Be sure to review these instructions to ensure you are properly completing CTRs.

CUAD School – Check Loss Prevention & Recovery Made Easy Explained Day 1

Join Ty Parker on May 19 and 20 in Bismarck as he breaks down check loss prevention and recovery. Since every credit union takes checks for deposit and issues its own cashier’s or teller’s checks (and most credit unions offer their members checking accounts), every credit union must know the information offered at this program in order to prevent and recover check losses and achieve all its key goals!


On Day 1 of this two day conference Ty will explain in plain-English the “check payment and return system” so critical to understanding check loss problems, and how to prevent and resolve all check nonpayment and fraud loss problems that occur from checks written or deposited by your members. This program will also address a number of advanced check loss issues including overdraft litigation, remote deposit capture (RDC) issues and the Regulation CC updates. Specific issues to be discussed at this program include:


✓ Mandatory pre-overdraft and overdraft explanations required to prevent litigation,

✓ All the major nonpayment check loss problems (NSF, Stop Pay, Overdrafts, Stale-dated checks),

✓ All the major fraud check loss problems (checks with alterations and forged signatures),

✓ All the latest remote deposit capture issues (both the good news and the bad news),

✓ The Regulation CC Update issues (both the good news and the bad news),

✓ How to place effective Reg CC & NON-Reg CC funds holds on checks that prevent losses,

✓ Stop payment, non-received and lost and stolen issues for checks,

✓ Truly understanding the consequences of the late return rule for your credit union (in all its roles),

✓ Shifting payment and fraud losses to member-drawers after final payment,

✓ A number of advanced nonpayment and fraud loss issues that all credit unions must know,

✓ And much much more!


Reserve your spot today! Additional details and registration can be found here. As always, CUAD members may contact Amy Kleinschmit with any compliance related questions.

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