Compliance Blog

By: Shannon Basile, Compliance Analyst On January 19, 2021, the Financial Crimes Enforcement Network (FinCEN) issued answers to frequently asked questions regarding SAR filings and other AML considerations with other federal regulators, including the NCUA. The topics covered include: Requests by law enforcement to maintain accounts where the financial institution has identified suspicious activity; A financial institution’s responsibility to file ...

By: Ashley Niebur Sharp, VP State Advocacy & Legislative Counsel Illinois legislators returned to Springfield for a “lame duck” session of the General Assembly on January 8-13, prior to new legislators being sworn into office. Priorities during the final days of the 101st General Assembly centered around the Legislative Black Caucus Agenda pillars: (1) Criminal Justice Reform; ...

By: Patrick Smith, SVP Regulatory Affairs As we start the new year, I wanted to make sure all our credit unions get off to a great start by reviewing NCUA’s top Supervisory Priorities for 2021. As in the past, many of these priorities are continued from previous years as they are still extremely relevant with respect to ...

By: Kari Osier, Compliance Specialist The attached Compliance Calendar provides compliance deadlines for the calendar year 2021. The Calendar is also posted on the League website in the Compliance section under Tools & Resources. 2021 Compliance Calendar  

By: Shannon Basile, Compliance Analyst Recently, the ICUL compliance team has received some questions regarding the proper way to respond to a subpoena. Specifically, when the subpoena is unclear or did not provide the credit union with a reasonable amount of time to respond. When reviewing and responding to a subpoena, it is important to understand all the ...

By: Joni Senkpeil, SVP Member Solutions Virtual Annual Meetings Recognizing COVID-19 will impact credit unions and their operation to varying degrees, the Illinois Department of Financial and Professional Regulation (IDFPR) and the National Credit Union Administration (NCUA) have extended relief measures related to conducting annual meetings. Please be aware the template provided by the Illinois Department of Financial ...

By: Kari Osier, Compliance Specialist On October 30, 2020, the CFPB issued part one of its final rule on debt collection (Regulation F, 12 CFR Part 1006), which focuses on debt collection communications and debt collector practices. The Compliance Team recently issued a Bulletin summarizing part one of the final rule. The CFPB will issue part two ...

By: Shannon Basile, Compliance Analyst In October, Nacha announced upcoming amendments to the Nacha Operating Rules with effective dates in 2021. The purpose of the amendments is to allow businesses, financial institutions, payment providers, and technology companies the ability to authorize consumer ACH payments using the various payment technologies available today. In addition, the new rules will ...

By: Ashley Niebur Sharp, VP State Advocacy & Legislative Counsel Credit unions historically enjoy a very positive reputation amongst staffers and elected officials in both Illinois and Washington, D.C. This is a direct result of the grassroots efforts by credit union officials throughout the state. In ordinary times, credit union staff members are engaging with elected ...

By: Kari Osier, Compliance Specialist Recently, the Compliance team has received a number of questions relating to repossession of collateral other than motor vehicles. Article 9 of the Illinois Uniform Commercial Code (“IL UCC”) (modeled after the Uniform Commercial Code), addresses the relationships between lenders, borrowers, and other third parties who may have an interest in ...