John Zasada, Compliance Consulting Director, Financial Institutions Group

On Jan. 18, 2022, the National Credit Union Administration (NCUA) issued Letter No: 22-CU-02 containing the NCUA’s Supervisory Priorities for 2022. Consistent with the past several years, one of the NCUA’s top Supervisory Priorities is the Bank Secrecy Act (BSA) and Anti-Money Laundering (AML)/Countering the Financing of Terrorism (CFT). Every NCUA exam includes BSA and AML/CFT reviews. The NCUA also pointed out that there will be several new BSA and AML/CFT requirements implemented in 2022. These requirements will necessitate updates to credit union’s BSA and AML/CFT policies, procedures and processes.

The NCUA also pointed out the following five other regulatory areas that will be a priority for examiners during examinations:

  1. The COVID-19 pandemic (mortgage forbearances, loan accommodations)
  2. Fair lending
  3. Servicemembers Civil Relief Act
  4. Fair Credit Reporting Act
  5. Overdraft programs

For more information on how this may impact your financial institutions, contact Doeren Mayhew’s regulatory compliance specialists.