No - the FFIEC manual has no impact on other state or federal law. While it suggests that a financial institution could close an account subject to repeated SARs, it would not apply if it would violate some other law or regulation.
NCUA Regulation: Closing Out Members Relationship
The NCUA has a regulation that will not allow a federal Credit Union to close out a member's relationship without being approved by the NCUA Board. However, the FFIEC manual allows for an institution to close out a member due to multiple SARs. Does the FFIEC Regulation supersede the NCUA regulation that requires approval before closing out a relationship?
First published on 09/22/2019