Newsroom
NAFCU Reg Alert examines FinCEN ANPRM on NAL program
NAFCU Wednesday sent members a Regulatory Alert breaking down and soliciting feedback on the Financial Crimes Enforcement Network's (FinCEN) advanced notice of proposed rulemaking (ANPRM) on creating a No-Action Letter (NAL) program.
The ANPRM notes that NALs would be “a letter indicating [FinCEN’s] intention not to take or recommend enforcement action against the submitting party for the specific conduct presented in the submitting party’s request.”
Through the Regulatory Alert, NAFCU highlighted:
- FinCEN's current mechanisms for obtaining regulatory guidance are not made public and therefore are not able to be widely used when developing and implementing new products or services;
- NALs essentially provide pre-approval from FinCEN to engage in certain activities; and
- NALs could aid in providing clarity when seeking to comply with Bank Secrecy Act requirements.
Comments in response to the ANPRM are due to NAFCU July 22 and can be submitted through the alert; comments are due to FinCEN Aug. 15.
Subscribe to receive Regulatory Alerts in your inbox.
Share This
Related Resources
Add to Calendar 2024-06-26 14:00:00 2024-06-26 14:00:00 Gallagher Executive Compensation and Benefits Survey About the Webinar The webinar will share trends in executive pay increases, annual bonuses, and nonqualified benefit plans. Learn how to use the data charts as well as make this data actionable in order to improve your retention strategy. You’ll hear directly from the survey project manager on how to maximize the data points to gain a competitive edge in the market. Key findings on: Total compensation by asset size Nonqualified benefit plans Bonus targets and metrics Prerequisites Demographics Board expenses Watch On-Demand Web NAFCU digital@nafcu.org America/New_York public
Gallagher Executive Compensation and Benefits Survey
preferred partner
Gallagher
Webinar
Add to Calendar 2024-06-21 09:00:00 2024-06-21 09:00:00 2024 Mid-Year Fraud Review Listen On: Key Takeaways: [01:16] Check fraud continues to be rampant across the country. Card fraud is affecting everyone. [04:31] Counterfeit US passport cards are just another new toolbox in the bad actors’ toolbox. [07:21] Blocking the fallback is the only way to defeat counterfeit cards. [11:17] The best way is constant education to your members in as many channels as you can. [13:02] We are still seeing overdraft lawsuits. Make sure the programming you have at your credit union matches what you have displayed for the members. Web NAFCU digital@nafcu.org America/New_York public
2024 Mid-Year Fraud Review
Strategy & Growth, Consumer Lending
preferred partner
Allied Solutions
Podcast
Add to Calendar 2024-06-21 09:00:00 2024-06-21 09:00:00 The Evolving Role of the CISO in Credit Unions Listen On: Key Takeaways: [01:30] Being able to properly implement risk management decisions, especially in the cyber age we live in, is incredibly important so CISOs have a lot of challenges here. [02:27] Having a leader who can really communicate cyber risks and understand how ready that institution is to deal with cyber events is incredibly important. [05:36] We need to be talking about risk openly. We need to be documenting and really understanding what remediating risk looks like and how you do that strategically. [16:38] Governance, risk, compliance, and adherence to regulatory controls are all being looked at much more closely. You are also seeing other technology that is coming into the fold directly responsible for helping CISOs navigate those waters. [18:28] The reaction from the governing bodies is directly related to the needs of the position. They’re trying to help make sure that we are positioned in a way that gets us the most possibility of success, maturing our postures and protecting the institutions. Web NAFCU digital@nafcu.org America/New_York public
The Evolving Role of the CISO in Credit Unions
preferred partner
DefenseStorm
Podcast
AI in Action: Redefining Disaster Preparedness and Financial Security
Strategy
preferred partner
Allied Solutions
Blog Post
Get daily updates.
Subscribe to NAFCU today.