Legal Briefs

Federal Reserve Board (Fed)
The Federal Reserve Board is requesting comments on proposed simplifications to Regulation D (Reserve Requirements of Depository Institutions).

National Credit Union Administration (NCUA)
The NCUA published letter to credit unions 11-CU-16 regarding the state of the credit union industry. The letter notes the strong start to 2011, as well as the NCUA’s concerns with excess risk, including credit, interest rate, concentration and strategic. The letter also includes a report analyzing trends over the first half of 2011. 

Financial Crimes Enforcement Network (FinCEN)
FinCEN has released the 20th issue of SAR Activity Review – Trends, Tips & Issues (October 2011), available here as a 94-page PDF file.

FinCEN has issued guidance regarding the reports of Foreign Financial Account (FBARs) requirements for former employees.

National Mortgage Licensing System (NMLS)
NMLS posted an online renewal handbook to guide institutions and their mortgage loan originators (MLO) through the SAFE Act renewal process. Both credit unions and MLOs will need to renew their registrations prior to Dec. 31, 2011. The new handbook provides the steps that both institutions and MLOs should follow to successfully complete this process. The NMLS has both a renewals web page and a frequently asked questions document to assist.

National Labor Relations Board
Posting of the employee rights notice is now required on Jan. 31, 2012. The NLRB postponed the deadline to allow for further education and outreach.


Questions? Contact the Compliance Hotline: 1.800.546.4465,

Posted in Compliance News, Federal.