ARTICLE
Compliance Update with Amy K by Amy Kleinschmit, Chief Compliance Officer Streamlined CDFI Application Opening Soon The National Credit Union Association has announced that its streamlined CDFI application will open September 12. This is for federally insured, low-income credit unions seeking a Community Development Financial Institution (CDFI) certification. CDFI-certified credit unions can apply for the CDFI Fund’s training and competitive award program that can enhance credit unions’ capacity to provide underserved communities with access to safe, affordable financial services. Links to the online application, along with instructions and additional details on CDFI can be found at the above link. FinCEN – 2020 SAR Data Available The Financial Crimes Enforcement Network’s (FinCEN) recently announced that its Interactive SAR Stats webpage has been updated to include Suspicious Activity Report (SAR) data by industry through the 2020 calendar year. Interactive SAR Stats is an application that enables users to view FinCEN’s trend data for aggregated counts of defined suspicious activities that financial institutions file with FinCEN as required by the Bank Secrecy Act. The new downloadable data is arranged by industry type, includes rankings by states/territories and suspicious activities, and is available here. Not surprisingly there was an increase in SAR filings last year, including here in the Dakotas. In 2020 ND depository institutions filed 2,123 SARs, compared to 1,717 SARs filed in 2019. FinCEN reported that SD depository institutions filed 31,623 SARs in 2020 which was an increase of 6,503 SARs compared to 2019. Use the “Interactive SAR Stats” found at the above link to drill down by regulator, suspicious activity category/type or other data points. Filtering by regulator type, SD credit unions filed 392 SARs in 2020, up from 248 SARs in 2019. ND credit unions filed 203 SARs in 2020, up from 116 SARs filed in 2019. Looking at SARs filed in 2020 by all depository institutions (not limited to the Dakotas), the top three types of suspicious activity selected were (1) transaction(s) below CTR threshold (319,981); (2) Suspicion concerning the source of funds (309,937); and transaction with no apparent economic, business or lawful purpose (271,138). For the most part ND and SD credit unions were in line with the national trend regarding suspicious activity type. SD top three suspicious activity types were: (1)transaction(s) below CTR threshold (169); suspicion concerning the source of funds (88); and check (51). ND credit unions’ top three selections for suspicious activity were transaction with no apparent economic, business or lawful purpose (47); transaction(s) below CTR threshold (47); and “other suspicious activities” (37). Remember – some SAR filings may list multiple suspicious activities. Obviously elder abuse continues to be a concern nationally, but also in the Dakotas. In 2020, SD credit unions filed 18 SARs relating to elder financial exploitation, compared to five in 2014. In total 310 SARs were filed relating to elder financial exploitation as reported by all SD depository institutions in 2020, which an increase of 96 compared to 2019. Interestingly, ND credit unions filed 15 SARs relating to elder financial exploitation in 2020, which is down from 19 SARs in 2019. However, the overall SARs filed relating to elder financial exploitation as reported by all ND depository institutions remained the same at 91 from 2019 to 2020. Another area of concern is human trafficking and human smuggling. In 2020 a total of 30 SARs identified human smuggling or trafficking as a suspicious activity as reported by all Dakota depository institutions (ND – 12; SD – 18). ACH fraud as a suspicious activity category/type took a jump last year among Dakota credit unions. This was selected as a suspicious activity 76 times by Dakota credit unions (ND – 33; SD – 43) in 2020. Compared to just 12 times in 2019 by Dakota credit unions (ND – 4; SD – 8). CFPB – Credit Card Agreement and Data Submissions The Consumer Financial Protection Bureau (CFPB) has announced new technical specifications for complying with certain submission requirements for credit card agreements and data to the CFPB under the Truth in Lending Act (TILA) and the Credit Card Accountability Responsibility and Disclosure Act of 2009 (CARD Act). Going forward, credit card issuers will make required submissions through the CFPB’s “Collect” website. Collect will be the mandatory vehicle for the Terms of Credit Card Plans (TCCP) Survey, quarterly credit card agreement submissions, and annual reports related to college credit card marketing agreements and data. These technical specifications include registration information and the URL for the website at which issuers (or their designees) can submit the required information. The CFPB’s credit card agreements and surveys webpage can be found here. Scam Targeting Employees The Federal Trade Commission (FTC) recently posted a notice regarding a phishing scheme that is targeting millions of people nationwide with texts aimed at stealing personal information, unemployment benefits, or both. As explained by the FTC, “The phishing texts try to dupe the recipient to click a link to “make necessary corrections” to their unemployment insurance (UI) claim, “verify” their personal information, or “reactivate” their UI benefits account. The link takes you to a fake state workforce agency website that may look very real. There, you’re asked to input your website credentials and personal information, like your Social Security number. Fraudsters can use the information to file fraudulent UI benefits claims or for other identity theft.” State agencies do not send text messages asking for personal information. As always, DakCU members may contact Amy Kleinschmit at akleinschmit@dakcu.org with any compliance related questions.
Compliance Update with Amy K
by Amy Kleinschmit, Chief Compliance Officer
Streamlined CDFI Application Opening Soon
The National Credit Union Association has announced that its streamlined CDFI application will open September 12. This is for federally insured, low-income credit unions seeking a Community Development Financial Institution (CDFI) certification.
CDFI-certified credit unions can apply for the CDFI Fund’s training and competitive award program that can enhance credit unions’ capacity to provide underserved communities with access to safe, affordable financial services. Links to the online application, along with instructions and additional details on CDFI can be found at the above link.
FinCEN – 2020 SAR Data Available
The Financial Crimes Enforcement Network’s (FinCEN) recently announced that its Interactive SAR Stats webpage has been updated to include Suspicious Activity Report (SAR) data by industry through the 2020 calendar year. Interactive SAR Stats is an application that enables users to view FinCEN’s trend data for aggregated counts of defined suspicious activities that financial institutions file with FinCEN as required by the Bank Secrecy Act. The new downloadable data is arranged by industry type, includes rankings by states/territories and suspicious activities, and is available here.
Not surprisingly there was an increase in SAR filings last year, including here in the Dakotas. In 2020 ND depository institutions filed 2,123 SARs, compared to 1,717 SARs filed in 2019. FinCEN reported that SD depository institutions filed 31,623 SARs in 2020 which was an increase of 6,503 SARs compared to 2019. Use the “Interactive SAR Stats” found at the above link to drill down by regulator, suspicious activity category/type or other data points. Filtering by regulator type, SD credit unions filed 392 SARs in 2020, up from 248 SARs in 2019. ND credit unions filed 203 SARs in 2020, up from 116 SARs filed in 2019.
Looking at SARs filed in 2020 by all depository institutions (not limited to the Dakotas), the top three types of suspicious activity selected were (1) transaction(s) below CTR threshold (319,981); (2) Suspicion concerning the source of funds (309,937); and transaction with no apparent economic, business or lawful purpose (271,138). For the most part ND and SD credit unions were in line with the national trend regarding suspicious activity type. SD top three suspicious activity types were: (1)transaction(s) below CTR threshold (169); suspicion concerning the source of funds (88); and check (51). ND credit unions’ top three selections for suspicious activity were transaction with no apparent economic, business or lawful purpose (47); transaction(s) below CTR threshold (47); and “other suspicious activities” (37). Remember – some SAR filings may list multiple suspicious activities.
Obviously elder abuse continues to be a concern nationally, but also in the Dakotas. In 2020, SD credit unions filed 18 SARs relating to elder financial exploitation, compared to five in 2014. In total 310 SARs were filed relating to elder financial exploitation as reported by all SD depository institutions in 2020, which an increase of 96 compared to 2019.
Interestingly, ND credit unions filed 15 SARs relating to elder financial exploitation in 2020, which is down from 19 SARs in 2019. However, the overall SARs filed relating to elder financial exploitation as reported by all ND depository institutions remained the same at 91 from 2019 to 2020.
Another area of concern is human trafficking and human smuggling. In 2020 a total of 30 SARs identified human smuggling or trafficking as a suspicious activity as reported by all Dakota depository institutions (ND – 12; SD – 18).
ACH fraud as a suspicious activity category/type took a jump last year among Dakota credit unions. This was selected as a suspicious activity 76 times by Dakota credit unions (ND – 33; SD – 43) in 2020. Compared to just 12 times in 2019 by Dakota credit unions (ND – 4; SD – 8).
CFPB – Credit Card Agreement and Data Submissions
The Consumer Financial Protection Bureau (CFPB) has announced new technical specifications for complying with certain submission requirements for credit card agreements and data to the CFPB under the Truth in Lending Act (TILA) and the Credit Card Accountability Responsibility and Disclosure Act of 2009 (CARD Act). Going forward, credit card issuers will make required submissions through the CFPB’s “Collect” website. Collect will be the mandatory vehicle for the Terms of Credit Card Plans (TCCP) Survey, quarterly credit card agreement submissions, and annual reports related to college credit card marketing agreements and data. These technical specifications include registration information and the URL for the website at which issuers (or their designees) can submit the required information.
The CFPB’s credit card agreements and surveys webpage can be found here.
Scam Targeting Employees
The Federal Trade Commission (FTC) recently posted a notice regarding a phishing scheme that is targeting millions of people nationwide with texts aimed at stealing personal information, unemployment benefits, or both.
As explained by the FTC, “The phishing texts try to dupe the recipient to click a link to “make necessary corrections” to their unemployment insurance (UI) claim, “verify” their personal information, or “reactivate” their UI benefits account. The link takes you to a fake state workforce agency website that may look very real. There, you’re asked to input your website credentials and personal information, like your Social Security number. Fraudsters can use the information to file fraudulent UI benefits claims or for other identity theft.”
State agencies do not send text messages asking for personal information.
As always, DakCU members may contact Amy Kleinschmit at akleinschmit@dakcu.org with any compliance related questions.