Skip to content
BOL Conferences
Thread Options
#2190900 - 08/28/18 06:31 PM NCUA Guidance to examiners on CDD Rule
Retired DQ Offline
10K Club
Retired DQ
Joined: Dec 2002
Posts: 40,766
Turnpike Exit 10
Snip: The NCUA recognizes that some credit unions may need additional time to implement changes and to fully comply with the new requirements. The NCUA examiners have been instructed to accept a credit union’s reasonable and good faith efforts to comply with the new rule throughout 2018. However, credit unions should understand that the NCUA’s acceptance of good faith efforts for supervision purposes does not shield a credit union from FinCEN penalties that could arise from failing to comply with all BSA/AML requirements.

https://www.ncua.gov/regulation-supervis...ns/2018/02.aspx

https://www.nafcu.org/newsroom/ncua-accept-good-faith-efforts-cdd-compliance

I wonder if the other agencies will follow suit.
_________________________
Get your facts first, then you can distort them as you please. - Mark Twain

Return to Top
BSA/AML/CIP/OFAC Forum
#2190914 - 08/28/18 07:36 PM Re: NCUA Guidance to examiners on CDD Rule Retired DQ
P*Q Offline

Power Poster
P*Q
Joined: May 2001
Posts: 8,458
Somewhere
Really??? Because as far as I knew, we had two years to comply and come 5/11/18 that was it. Wouldn't surprise me if the other agencies didn't follow suit....

Return to Top
#2190924 - 08/28/18 08:12 PM Re: NCUA Guidance to examiners on CDD Rule Retired DQ
Retired DQ Offline
10K Club
Retired DQ
Joined: Dec 2002
Posts: 40,766
Turnpike Exit 10
PQ, shhh, that date was only for banks, not CUs... laugh
_________________________
Get your facts first, then you can distort them as you please. - Mark Twain

Return to Top
#2190934 - 08/28/18 08:40 PM Re: NCUA Guidance to examiners on CDD Rule Retired DQ
LiveFunLife Offline
Member
Joined: Dec 2017
Posts: 91
I took over in January of this year as an army of one. My institution literally didn't even start the project. I finished it with training before May. On May 11th I sat back with a drink and did other work lol. The ones who are not prepared chose to be that way.

For major companies like a Wells Fargo I haven't even a guess of how hard it would be to comply but two years is plenty I bet.

Return to Top
#2190949 - 08/28/18 09:29 PM Re: NCUA Guidance to examiners on CDD Rule Retired DQ
Reg Warrior Online
100 Club
Joined: Jan 2017
Posts: 214
This little CU revised forms, updated procedures, and conducted training in order to be ready by the May deadline. The NCUA will soon be in our little corner of the world and have requested every policy, procedure, form, and reports we have that has to do with BSA/CDD. So, we will see how "lenient" the NCUA will be in their review.

Return to Top
#2191063 - 08/29/18 05:05 PM Re: NCUA Guidance to examiners on CDD Rule Retired DQ
P*Q Offline

Power Poster
P*Q
Joined: May 2001
Posts: 8,458
Somewhere
Originally Posted By DeeQ
PQ, shhh, that date was only for banks, not CUs... laugh
laugh laugh

Return to Top
#2191173 - 08/30/18 01:25 PM Re: NCUA Guidance to examiners on CDD Rule Retired DQ
Pat Patriot Act Offline
Gold Star
Pat Patriot Act
Joined: Apr 2009
Posts: 450
I'm surprised anyone from the NCUA stopped napping long enough to write anything.
_________________________
CFE, CAMS

Return to Top

Moderator:  Andy_Z