Compliance Update with Amy K
by Amy Kleinschmit
Chief Compliance Officer
1/15/2021

EIP2

Earlier this week the IRS issued an updated statement on economic payments.

“The IRS continues to take additional steps to get the second Economic Impact Payments to more eligible taxpayers. In addition to redirecting payments to the proper account in recent days to a larger group of people, the IRS and tax industry partners worked over the weekend to help a smaller set of impacted taxpayers.

Reissuance of Certain Economic Impact Payments - Following extensive work and discussions with our industry partners, the IRS will reissue payments for taxpayers who did not receive the second Economic Impact Payment because the temporary bank accounts identified in our records were closed.

Taxpayers Impacted - This impacts some taxpayers when tax preparation providers were unable to deliver funds to people as a result of IRS guidance, and they are now waiting for the IRS to re-process payments related to these accounts.

Payment Directly from the Government to be Received Soon - Payments will be issued directly from the government later this month (our industry partners are not in possession of these funds), within weeks of the law being enacted.  For people in this group, payments may be issued either as a paper check or as a direct deposit.

No Action Required by Taxpayers to Receive these Payments - Taxpayers do not need to take any action or call; the payments will be made automatically.”

 

Verifying Stimulus Payments

Please visit tcva.fiscal.treasury.gov to learn about the security features in U.S. Treasury checks and the Treasury Check Verification Application (TCVA). TCVA is a tool to help the financial industry verify U.S. Treasury checks and assist in fraud detection. TCVA provides the capability for single queries and the Treasury Check Verification Service (TCVS) provides capabilities for single and bulk queries using an API.

Financial institutions are liable for the payee’s endorsement. Financial institutions using the TCVA or TCVS still need to verify the security features of a US Treasury Check. As a reminder, TCVA and TCVS are unable to provide assurance that the check being presented is genuine (not counterfeit) or that it is properly payable.

The Treasury has issued a number of FAQs for financial institutions regarding the EIP2 which you can find here

 

CDFI

Has your credit union looked at becoming a Community Development Financial Institution (CDFI)? Why not?

The National Credit Union Administration (NCUA) has announced that federally insured, low-income credit unions seeking Community Development Financial Institution certification can apply to use the National Credit Union Administration’s streamlined qualification process beginning January 24.

CDFI certification makes credit unions eligible for CDFI Fund training and competitive award programs that enhance their capacity to provide underserved communities with access to insured, affordable financial services. The Consolidated Appropriations Act, 2021 authorizes additional COVID-19 relief funding for community development financial institutions that predominantly serve minority communities. Approximately a third of this additional funding includes a set aside for smaller financial institutions with less than $2 billion in assets.

The NCUA provides a number of resources for credit unions considering a CDFI certification which can be found here, including FAQs, a video, fact sheet, and how to apply. The NCUA program guide has instructions explaining the streamlined qualification process. The deadline for streamlined certification applications is April 3.

 

NCUA – Letter to FCUs

The NCUA recently issued a Letter to Federal Credit Unions 21-FCU-03 regarding underserved area expansions. As explained in the Letter, Any federal credit union with a multiple common bond field of membership may include in its field of membership, without regard to location, underserved communities as defined by the Federal Credit Union Act. To promote greater financial inclusion and strengthen communities, the NCUA encourages such credit unions to expand their service to underserved areas.”

 

InfoSight Highlight – 2021 Compliance Calendar

With a new year comes a lot of new changes, so be sure you check the 2021 Compliance Calendar to be sure you are in compliance when the dates arrive. Here’s a quick look at the first six months of the year (subject to change):

January 1st, 2021: Annual Updates

January 1st, 2021: Annual Reg Z Inflation Adjustments - Effective Date

January 1st, 2021: NACHA – Enforcement

January 31st, 2021: 5300 Call Report Due to NCUA

March 1st, 2021: Mandatory Use of Updated the Uniform Residential Loan Application (URLA)

March 1st, 2021: March 1, 2021 – HMDA submission deadline

March 19th, 2021: Expanding Same Day ACH Effective Date (Date Extended)

June 30th, 2021: NACHA – Limitation on Warranty Claims

June 30th, 2021: NACHA – Reversals

 

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

 

 

<< Go to Memo List