NCUA recently published a letter to credit unions (18-CU-02) that discusses NCUA’s exam expectations in light of the effective date of the new Customer Due Diligence and Beneficial Ownership rules. While the rule became effective May 11, 2018, field staff will focus on a credit union’s awareness of and efforts to comply with the new rules.
The letter notes that while ARIES will be updated to include these new requirements in September, NCUA will not identify compliance lapses during examination with these new BSA requirements for the remainder of 2018, “provided the credit union is making a good faith effort to comply with the new rules.” However, expect NCUA to review compliance with the new rules in depth in 2019.
The letter includes several important resources. The first is a BSA questionnaire, which is a great rubric for evaluating your credit union’s BSA compliance program. The other resources are the addendum on the new rules that are to be incorporated in the FFIEC BSA Exam Manual. These additions offer an overview of the regulations and a thorough review of the expectations regulators have for the credit union’s compliance program.
If you have any questions regarding this letter and the new rule changes, please contact Mike Lee, Director of Regulatory Advocacy at Michael.firstname.lastname@example.org.