Regulatory Compliance Weekly Roundup: December 21, 2023

Happy…Thursday everyone! With the holidays upon us, the weekly roundup is one day early this week! Here's a quick overview of some of the headlines from the week in regulatory compliance.

NCUA

Last night the U.S. Senate confirmed the nomination of Tanya Otsuka for the NCUA Board. Once sworn in, she will replace current Board Member Rodney Hood on the three-person NCUA Board. She brings a wealth of experience from both the Senate Banking Committee as well as the FDIC and will be a valuable addition to the NCUA Board. We look forward to working with her on credit union issues in 2024 and beyond.

The agency also released state-level data for Q3 2023 yesterday. This data provides useful information and insight into credit union trends.

Finally, the NCUA released the new version of the Simplified CECL Tool. Now their site shows the December 2023 version as available for download. But if you need past versions, don't worry - they are available for download as well from the same page.

FinCEN

We've blogged here before about the FinCEN Beneficial Ownership Information rulemaking process. While FinCEN has released some guidance for businesses in the past few months about how they will submit beneficial ownership information to the BOI database, credit unions have been waiting for the "Access Rule" addressing when financial institutions may/must access the database and other questions.

The Access Rule was released this morning, along with a YouTube video with additional details. The financial regulators also issued a joint statement providing additional clarification for financial institutions. The statement clarifies that this new rule does not make any changes to a financial institution's responsibilities under the BSA or the CDD Rule, nor are there any new supervisory expectations.

We'll have a more detailed analysis of the Access Rule in the coming weeks as we are able to fully review and process it.