Expiring ITINs Can be Renewed Now for 2018


The IRS recently announced that it is accepting renewal applications for the ITINs set to expire at the end of 2017. This renewal process is beginning three months earlier than last year to make the process easier for taxpayers.

Under the Protecting Americans from Tax Hikes (PATH) Act, ITINs that have not been used on a federal tax return at least once in the last three consecutive years will expire Dec. 31, 2017, and ITINs with middle digits 70, 71, 72, or 80 will also expire at the end of the year, even if the taxpayer has used it in the last three years. Affected taxpayers who expect to file a tax return in 2018 must complete a Form W-7 and submit all required documentation.

Federal returns submitted in 2018 with an expired ITIN will be processed. However, exemptions and/or certain tax credits will be disallowed.

In this recent notice, the IRS also reminds us that it no longer accepts passports that do not have a date of entry into the U.S. as a stand-alone identification document for dependents from a country other than Canada or Mexico, or dependents of U.S. military personnel overseas. The dependent’s passport must have a date of entry stamp, otherwise the following additional documents to prove U.S. residency are required:

  • U.S. medical records for dependents under age 6,
  • U.S. school records for dependents under age 18, and
  • U.S. school records (if a student), rental statements, bank statements or utility bills listing the applicant’s name and U.S. address, if over age 18.

For more information, see IR-2017-109.

Source:  IRS

Question of the Week

We are looking at making a loan on a piece of property. The member has an appraisal that was completed by an approved appraiser three months ago for another financial institution that turned them down for the loan. Can we use that appraisal?

Generally, a credit union should not rely on an evaluation prepared by or for another institution because it will not have sufficient information relative to that institution’s risk management practices for developing evaluations.  That said, a credit union may use an appraisal prepared by an appraiser directly engaged by another financial services institution, provided the credit union determines that the appraisal conforms to relevant appraisal regulations and your own credit union’s standards.  Your credit union should independently assess the appraisal with the same level of review it would for an appraisal obtained directly from similar properties, and document its review, before making the credit decision. This includes confirming that the appraisal was engaged directly by the other financial services institution and it, rather than the potential borrower, ordered the appraisal, that the appraiser had no direct, indirect, or prospective interest, financial or otherwise, in the transaction.

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Legal Briefs

National Credit Union Administration (NCUA)

The NCUA announced that Acting Chairman McWatters has been named the NCUA Chairman.

Consumer Financial Protection Bureau (CFPB)

CFPB Director Cordray delivered prepared remarks at the American Association of Family and Consumer Sciences conference. Cordray’s remarks focused on the steps the CFPB is taking to protect consumers in the financial marketplace.

The CFPB announced that they are filing two complaints and proposed final judgments against four credit repair companies for misleading consumers and charging illegal fees.

The CFPB released a special edition of its monthly complaint report. This report shows that over half of consumers submitting complaints opt to have their narratives published, debt collection and mortgage company complaints make up ½ of the complaints submitted, and 97% of the time, companies provided a timely response to complaints received from the CFPB.

Federal Reserve Board (FRB)

The FRB released the results of its Comprehensive Capital Analysis and Review (CCAR). Of the 34 holding companies that participated, only one is being required to address weaknesses in its capital planning process.

The FRB released its annual determination of aggregate consolidated liabilities of financial companies.

Federal Deposit Insurance Corporation (FDIC)

FDIC issued FIL-24-2017 to explain the proposed revisions to the Consolidated Reports of Condition and Income (Call Report). The Call Report proposal was issued by the FDIC, OCC, and FRB.

Office of Comptroller of the Currency (OCC)

The OCC announced updates to its Branch Closings booklet.

Federal Housing Finance Agency (FHFA)

The FHFA announced that its index showed that the mortgage rates decreased in May.

Office of Foreign Assets Control (OFAC)

OFAC has updated the SDN list as of June 29, 2017. The last update prior to this was June 26, 2017.

Questions? Contact the Compliance Hotline: 1.800.546.4465; compliance@nwcua.org.

Posted in Compliance News, Compliance News.