Compliance Update with Amy K
by Amy Kleinschmit
Chief Compliance Officer

Proposed ND Admin Code. The North Dakota State Credit Union Board has issued its notice to adopt/amend/repeal various sections of the North Dakota Administrative Code. A hearing on these changes will be held August 30, 2018. However, written or oral comments on the proposed rules may be sent to the address, telephone number, or email address listed within the notice and must be received no later than September 12, 2018 to be considered. The notice can be found here and includes a high-level summary of the changes to the various sections. The proposed changes can be found here.

FinCEN Limited Exception Extension. FinCEN is extending the limited exception for an additional 30 days, up to and including September 8, 2018 from the obligations of the Beneficial Ownership Rule for rollover or renewal of certain financial products and services (i.e., certificate of deposit or loan accounts) that were established before May 11, 2018 to further consider the issue. This announcement can be found here.

InfoSight Highlight. Recent Update – Employment Channel. A new topic, Executive Compensation: Tax Cuts and Jobs Act of 2017 has been added to the Employment Channel. This is an overview of the Tax Cuts and Jobs Act of 2017 [TCJA] which imposes an excise tax on certain executive compensation provided by tax-exempt organizations.

The TCJA made significant changes to our nation’s tax laws. Although it provided tax cuts in many areas and maintained the federal tax exemption for state and federal credit unions, the law negatively impacted credit unions in the area of executive compensation. Read more about these changes here.

FREE Webinar. CUAD has partnered with Pay Lynxs to deliver SimpliRisk for BSA/AML automation – another option in your compliance toolbox. Join us for a free 30 minute webinar for Credit Union Association of the Dakotas members on Tuesday, September 25 at 2:00 p.m. CT.  

Pay Lynxs is a software company that provides fraud detection, anti-money laundering and risk rating solutions to help credit unions fight financial crimes, money laundering and identify high risk activity through innovative technology. Their cloud-based software solution, SimpliRisk, offers credit unions an alternative to manual compliance procedures by automating AML/BSA and risk management procedures. 

This webinar will showcase how SimpliRisk can streamline and simplify your BSA/AML Compliance process. We will focus on Fraud Detection, Member/ Business account Risk Rating, Case Management, OFAC Scanning and setting up and supporting your FinCEN required CDD program to meet the new AML Program requirements.

Pay Lynxs' dedication to the credit unions in the Dakotas is evident in their commitment to offer affordable, flexible solutions to our members to automate AML and BSA risk management procedures. Pay Lynxs’ software platform, SimpliRisk, enables credit unions to customize their transaction rules and define their own unique member risk rating model, using SimpliRisk open architecture that supports easy configuration and full transparency.

Register for this FREE event here.

HDMA Tool. The CFPB recently announced the release of the File Format Verification Tool (FFVT) for HMDA data collected in 2018 and submitted in 2019. The FFVT is a resource for testing whether the HMDA file meets certain formatting requirements specified in the HMDA Filing Instructions Guide (FIG).

The FFVT was developed with no login functions, and does not log identifying information about FFVT users or the files they upload. The FFVT simply allows HMDA filers to test the formatting of their files. Thus, no Federal agency will receive or be able to view the files you test using it.

The CFPB also announced the availability of the 2017 HMDA Dynamic National Loan-Level Dataset and the Aggregate & Disclosure reports on the FFIEC HMDA Platform Data Publication web page.

The Dynamic National Loan-Level Dataset is updated weekly to include late submissions and resubmissions. Loan/Application Register (LAR) and Transmittal Sheet (TS) records are available separately.  The National Aggregate reports summarize lending nationwide, the Aggregate reports summarize lending by MSA/MD, and the Disclosure reports summarize lending by institution, both nationwide and by MSA/MD.


As always, CUAD members may contact Amy Kleinschmit for assistance with any compliance related questions.


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