The NCUA Posts New Share Insurance Fund Equity Distribution FAQs

Federally insured credit unions in the Northwest can find online information about calculating and recording the planned Share Insurance Fund equity distribution plan.

4/10/18

picture of national credit union administration officeThe National Credit Union Administration (NCUA) posted new frequently asked questions about the distribution that include a preliminary pro rata calculation figure and instructions for recording the distribution, available online here.

The pro rata calculation figure is subject to change, and the NCUA claims no responsibility for an eligible credit union’s accounting estimate of its Share Insurance Fund equity distribution.

Following the closure of the Temporary Corporate Credit Union Stabilization Fund and the transfer of assets to the Share Insurance Fund on Oct. 1, 2017, the NCUA Board, at its February 2018 open meeting, authorized a statutorily required Share Insurance Fund equity distribution of $736 million to eligible credit unions, to be paid in the third quarter of 2018.

Question of the Week

If a member deposits a check to a savings account, can the credit union place a hold on it if the hold is deemed necessary?

Yes, a reasonable hold can be placed on a check deposited to a savings account.

Reg CC check hold rules apply to “accounts,” which is defined as generally including accounts at a credit union from which the member is permitted to make transfers or withdrawals by negotiable or transferable instrument, payment order of withdrawal, or other similar means for the purpose of making payments or transfers to third persons or others.  An account also includes accounts from which the member may make third party payments at an ATM, remote service unit, or other electronic device, including by debit card, but the term does not include savings deposits.

Therefore, since Reg CC does not apply to savings deposits. Checks deposited into a savings accounts do not have to have holds placed on them. However, a credit union can place a reasonable hold on a check deposited to a savings account, as Reg CC doesn’t prohibit this. If there are doubts about the collectability of checks, a hold long enough to determine if the check is going to be paid might be a good idea. The credit union can use this time to determine if the check will be returned by the midnight deadline or make phone calls to try and determine the legitimacy of the checks issuance.

It is also important to note that while Reg CC does not apply to savings account, credit unions should check their membership and account agreements and/or their Funds Availability Policy to ensure that they don’t make savings deposits subject to Reg CC provisions by way of their agreement/policy.

Related Links

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National Credit Union Administration (NCUA)

The March 2018 NCUA Board Meeting video is now available.

Consumer Financial Protection Bureau (CFPB)

The CFPB issued a Request for Information regarding its consumer financial information.

Federal Housing Finance Agency (FHFA)

The FHFA announced that it is seeking comments for its regulatory review.

Financial Crime Enforcement Network (FinCEN)

FinCEN released FAQs to help financial institutions better understand how to comply with the Beneficial Owner Rule that takes effect on May 11, 2018.

Office of Foreign Assets Control (OFAC)

OFAC has updated the SDN list as of April 6, 2018. The last update prior to this was April 3, 2018.

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