On January 7, 2020, the National Credit Union Administration (NCUA) announced their 2020 supervisory priorities. The top two 2020 supervisory priorities are the Bank Secrecy Act (BSA) and consumer compliance. BSA and consumer compliance are higher priorities than even cybersecurity and credit risk.  BSA is reviewed during every examination. Top areas of BSA focus continue to be customer due diligence, beneficial ownership and the proper filing of SARs and CTRs. NCUA will be working with the Federal Financial Institutions Examination Council (FFIEC) to update the Bank Secrecy Act/Anti Money Laundering Examination Manual. In terms of consumer compliance, NCUA stated every exam includes compliance with applicable consumer financial protection regulations. NCUA examiners are required this year, at a minimum, to cover the following consumer protection requirements:

  • Regulation E
  • Regulation Z
  • Fair Credit Reporting Act
  • Privacy Act
  • Payday Alternative Lending
  • Military Lending Act and Servicemembers Civil Relief Act


John Zasada, JD, CAMS – Compliance Consulting Director, Financial Institutions Group. John can be reached at zasada@doeren.com.