Compliance Update with Amy K
by Amy Kleinschmit
Chief Compliance Officer

FREE Webinar – NCUA’s Response to COVID-19

Federally insured credit unions can learn more about the National Credit Union Administration’s response to the COVID-19 pandemic by participating in a webinar hosted by the agency on Thursday, December 3, beginning at 12:00 p.m. (CT). During the webinar, NCUA staff will also discuss recently issued guidance and regulations, as well as other agency initiatives.

Register for this event here. Registration is limited to no more than 2,500 participants on a first-come, first-served basis. Participants may submit questions in advance to by noon Eastern on Wednesday, December 2. The email’s subject line should read “NCUA COVID-19 Update.”

Consumer Compliance Outlook

The Federal Reserve has issued its third issue of Consumer Compliance Outlook for 2020 which can be found here. Consumer Compliance Outlook is a Federal Reserve System publication dedicated to consumer compliance issues, they also offer a number of free webinars on various rules/regulations – one of which is upcoming and discussed below, but are also are archived at the above link.

This particular issue leads with an article on The Benefits of a Proactive Compliance Program which discusses that a compliance management system can help prevent problems later and can help save money by identifying and preventing possible issues early – fixing things later can get expensive and negatively impact reputation.

Another article that caught my attention was Effective Bank Communications Enhance Compliance and Customer Satisfaction, which discusses how to assess consumer compliance risks in customer/member communications. Assessing risk begins with identifying all the communication channels being used, and the articles give a number of examples of all the different types of communication that may be involved. It goes on to explain that, “after the communication methods are identified, it may be appropriate to concentrate compliance resources on the types of communications most likely to result in consumer harm or pose the highest risk of not complying with federal consumer protection laws and regulations.”

All the points raised in the article are important, but it is important to emphasize the point regarding protecting member/customer privacy which reminds that “privacy requirements cover written and oral communications that may range from email transmissions to conversations in a branch lobby.” An example given stresses this point, “a teller who orally states the balance remaining in a customer’s account or the amount of funds being withdrawn in a manner that may be clearly overheard by others in the lobby. This could expose the customer’s nonpublic personal information to other customers or potential fraudsters and violate privacy and other consumer protection laws and regulations.”

Nacha – ACH Operations Bulletin #7-2020

In response to COVID-19, Nacha has issued several ACH Operations Bulletins and Frequently Asked Questions announcing relief from a variety of requirements of the Nacha Operating Rules. This ACH Operations Bulletin provides an update on the status of that relief, as well as information on upcoming effective dates of new Nacha Rules and other ACH requirements.

There are two specific dates to draw your attention to; however, there are several others discussed in the Bulletin that you need to be aware of.

October 30, 2020 – Deadline for all depository financial institutions participating in the ACH Network to register contact information in the ACH Contact Registry. Nacha will not enforce this rule for an additional period of nine months, through July 31, 2021, during which non-compliant institutions can register without any enforcement action.

December 31, 2020 – Deadline for covered parties to complete their annual ACH Rules Compliance Audit.

FREE Webinar - 2020 Fair Lending Interagency Webinar

On Tuesday, December 8, 2020, at 1:00 p.m. (CT) eight federal agencies, including the National Credit Union Administration, will be discussing a variety of fair lending topics, including recent agency actions and examples of credit discrimination in different contexts. The presentation will be followed by a Questions and Answers segment, where the agencies will respond to questions. To facilitate this session, please send in your questions in advance of the webinar via e-mail.

Please click on the URL or copy and paste it into your browser to register for this webinar:

This webinar is part of the ongoing series of events focused specifically on consumer compliance topics. The “Outlook Live” webinar series is a Federal Reserve System initiative produced in conjunction with the Federal Reserve System’s newsletter Consumer Compliance Outlook.

InfoSight Highlight – RISK Alerts added!

In a new collaboration with CUNA Mutual Group, RISK Alerts & Resources are now available on InfoSight! RISK Alerts from CUNA Mutual Group are written by industry experts and are published just-in-time when risks are most prevalent to make sure credit unions are on top of the most relevant topics. Additional Risk Resources from CUNA Mutual Group provide credit unions with actionable insights and proven risk mitigation guidance to help credit unions stay on top of emerging risks. Find these new resources under the “resources” tab within InfoSight.

Just a friendly reminder that InfoSight is a dues-supported solution our member credit unions can use to meet today’s credit union challenges. This free resource provides an online destination for a wealth of information. Receive access to many different credit union areas with links to applicable laws, regulations, resources, checklists, easy-to-read summaries, and more! Information covering over 25 topics specific to each state has been developed by the Leduc Frank Law Firm, in addition to direct collaboration with other state credit union Leagues and Associations to provide the most current and reliable state-specific information for the ever-evolving financial institution landscape.

Local laws, additional resources and frequently asked questions all offer users information specific to their region. With unlimited user capability, all employees and volunteers are encouraged to discover everything this platform has to offer. Users will be able to customize their dashboard allowing the individual credit union employee or volunteer immediate access to the topics that matter most to their position. Credit union users can now explore information by topic with easy-to-navigate content in a format everyone can understand.

Access your InfoSight resource here, or request your DakCU member account under the login information:

As always, DakCU members may contact Amy Kleinschmit with any compliance related questions.



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