Compliance Update with Amy K
by Amy Kleinschmit
Chief Compliance Officer

IRS – Economic Impact Payments (EIP)

The IRS continues to periodically update the guidance regarding EIPs. Earlier this month the IRS updated Q13 to discuss uncashed EIP checks issued to ineligible recipients. The Bureau of Fiscal Services (BFS) has cancelled outstanding Economic Impact Payment (EIP) checks issued to recipients who may not be eligible, including those who may be deceased. Treasury is encouraging financial institutions and other check cashing entities to determine the status of EIP checks by using Treasury check verification tools.

An EIP made to someone who died before receipt of the EIP should be returned to the IRS by following the instructions in the Economic Impact Payments FAQs on Recipients should return these checks as described in Returning the Economic Impact Payment section.

Also, if you have heard anyone say their check was mailed on May 22, but they still haven’t received it, apparently, there was a system error. EIPs scheduled to be mailed as a pre-paid debit card on 05/22/2020 were not all issued. Several states were impacted including North Dakota and South Dakota. Per the IRS website, they are working to issue the payment as a paper check to the recipient's address on file. Get My Payment will provide a new date once the payment by check has been scheduled.

Finally, the IRS is wanting to make sure everyone knows about the EIP. There is an October 15 deadline to use the non-filer tool. Millions of low-income people and others who aren't required to file a tax return may be eligible for an Economic Impact Payment and can easily register for a payment by using the free Non-Filers tool, available only on

The Non-Filers tool is designed for people with incomes typically below $24,400 for married couples, and $12,200 for singles. This includes couples and individuals who are homeless. People can qualify, even if they do not have earned income or work. Usually, married couples qualify to receive a $2,400 payment while others normally qualify to get $1,200. People with qualifying children under 17 can get up to an additional $500 for each child. Anyone who already filed either a 2018 or 2019 return does not qualify to use this tool.

Here are some resources to help get the word out:



This would be good information to share with food banks, churches, shelters, etc.


NACHA - ACH Contact Registry

The ACH Contact Registry was created for financial institutions to efficiently connect with other financial institutions about ACH operations, exceptions and risk management. Registration is now open via the Risk Management Portal.

Beginning July 1, 2020, all financial institutions participating in the ACH Network are required to register contact information with Nacha for personnel or departments responsible for ACH operations and fraud/risk management. The contact information will be available for other registered ACH participating financial institutions, Payments Associations, the ACH Operators, and Nacha for operational, fraud, and risk management issues in the ACH Network (e.g., proof of authorizations, ACH-related system outages, erroneous payments, duplicates, reversals, fraudulent payments, etc.). Contact information will only be for those parties' own, internal use and limited to these purposes.

Deadline to register is October 30, 2020.

Additional FAQs can be found here:


Recent Regulatory Changes

July 1st, 2020: Regulation C – Home Mortgage Disclosure Act (HMDA) - Increased the threshold for reporting data about closed-end mortgage loans so that credit union originating fewer than 100 in either of the two preceding calendar years will not have to report such data.  This is an increase from the current 25 closed-end limit for reporting. (Open-end threshold will decrease January 1, 2022 to 200 from the current 500).

July 1st, 2020: Regulation CC – Monetary Limit Threshold Changes. Threshold changes under Regulation CC will change every 5 years, first adjustment was effective July 1. The credit union is required to send out a change in terms notice no later than 30 days after implementation of the limits. Affected next day availability; large deposit, new accounts and repeated overdraft limits; and special rules for cash withdrawals.

July 21st, 2020: Remittance Transfers (Regulation E) Amendments to allow certain exceptions when using estimates instead of exact amounts.  The safe harbor threshold in the rule increased from 100 to 500.  If the credit union has provided 500 or fewer remittance transfers in the previous and current calendar year, they are provided a safe harbor and not considered a remittance transfer provider under the rules.


InfoSight Highlight - Where can you find what you are looking for?

Check out the Resources area on InfoSight for many tools and helpful information. For instance:

A-Z Listing: This is a great way to easily find a topic you are seeking, even if you don’t know exactly which channel it might reside under. 

InfoSight Listing by State: InfoSight is available in all 50 states and includes state-specific information for each one! Use the InfoSight Listing by State to easily connect if you need to check the requirements in other states.

Newsletter: View the current newsletter and the archived editions for this year and the prior year.


Remember – not all treasure is silver and gold, mate.” ~ Pirates of the Caribbean.

Have a wonderful weekend, if you have any questions please do not hesitate to contact me, Amy Kleinschmit.


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