On Compliance: Fewer changes, more enforcement possible in 2019

2019 will be an interesting year for regulatory compliance. Unlike the past couple of years, we are not facing major regulatory changes. At the same time, we could perhaps have a slight shifting in Washington toward more regulatory enforcement, although that is far from certain. In addition, there are indications credit union examiners may focus more on regulatory compliance during exams this year.  All told, I think it is important in 2019 to pay particular attention to the areas below.

1. BSA

I know this may seem redundant, but trust me, the Bank Secrecy Act still matters, maybe more so than ever. Examiners are looking deeper into it; expectations are increasing; and violations are being found. In fact, when the National Credit Union Administration laid out its supervisory priorities for 2019, the very first one it listed was BSA. NCUA specifically mentioned customer (member) due diligence and beneficial ownership rules as areas on which examiners will perform more in-depth reviews. Our compliance consultants are finding an increasing number of violations in both of those areas.

 

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