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In 2018, NAFCU and the industry made progress on a number of issues to ensure regulatory and legislative environments in which credit unions can grow and thrive. NAFCU's compliance team works daily to provide credit unions with the information and resources they need to stay compliant in these ever-changing environments. Here are some of the top issues of 2018.

Bank Secrecy Act

NAFCU's compliance team has myriad resources to help credit unions comply with Bank Secrecy Act (BSA) requirements. A widely referenced NAFCU Compliance Blog post provides credit unions with updated civil monetary penalty amounts the Financial Crimes Enforcement Network (FinCEN) can impose on credit unions and individuals for violating anti-money laundering (AML) and terrorist financing laws.

The May 11, 2018, compliance deadline for FinCEN's customer due diligence (CDD) and beneficial ownership rule also posed concerns for credit unions; NAFCU's compliance blog features explanations on examination guidance, exemptions for account rollovers and renewals, and how the rule works with Office of Foreign Assets Control (OFAC) requirements.

NAFCU is supportive of efforts to provide credit unions with regulatory relief under BSA requirements. NAFCU witness John Lewis testified before a House Financial Services subcommittee last year and spoke in favor of legislation that would modernize the BSA/AML regime, and the association also offered support for a bill last Congress that would increase reporting thresholds for currency transaction reports (CTRs) and suspicious activity reports (SARs).

Economic Growth, Regulatory Relief, and Consumer Protection Act (S. 2155)

NAFCU's award-winning advocacy team secured the credit union industry's first meeting with President Donald Trump at the White House last year, which helped ensure the president's support for S. 2155.

Following the legislation's enactment, NAFCU's compliance team explained the law's impact on credit unions, including changes to Home Mortgage Disclosure Act (HMDA) reporting requirements, member business loan (MBL) caps and qualified mortgages, to name a few. The team also explained the identification provision that allows credit unions to copy state-issued IDs for online services. NAFCU continues to update its summary guide as agencies, including the NCUA and Bureau of Consumer Financial Protection, work to implement S. 2155's provisions.

TILA/RESPA integrated mortgage disclosure (TRID) rule

The bureau finalized a NAFCU-sought amendment to resolve the "black hole" issue under its TRID rule; a popular NAFCU Compliance Blog post further explained the black hole and how the amendment resolves it. NAFCU had advocated in support of the fix because of the compliance challenges, confusion, and increased flexibility for credit unions to honor last-minute loan changes without unfairly absorbing costs.

NAFCU has various other resources available on TRID, including another popular blog related to statutory damages and errors in the loan estimate or closing disclosure.

NAFCU's compliance team works tirelessly to provide support and resources for all issues facing credit unions, including unclear website accessibility standards under the Americans with Disabilities Act (ADA), remote deposit capture rules and alleged patent infringement, HMDA reporting, marijuana banking and more.

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