CCUL Headlines: Compliance

CCUL Compliance: stay on track with a year-end compliance checklist

Thursday, October 12, 2017   (0 Comments)
Posted by: Trichina Pierce, CCUL Compliance
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Stores are filled with Halloween costumes, fall festival decorations, and yes, Christmas decorations too. It’s official, we are well into the third quarter of this calendar year, which means winter break is just around the corner and yet there are still many regulations, policies and procedures to review.

If you’re like me, you notice time flies faster year after year. Pretty soon, 2018 will be here and you will be diligently working to document the final status on your compliance deliverables. Who wants to be saddled with extra work around the holidays? Not Me! So, I decided to take 5 minutes right now to run down my mental checklist to ensure things are on track.

In case you can’t remember everything on your list, here’s a brief year-end checklist to make sure your compliance initiatives are still on track and your holidays remain free of work!

Compliance Initiatives Year-End Checklist:

  • Q1-Q3 HMDA data reconciled and accurate.
  • Q1-Q3 scheduled policy reviews took place and appropriate approvals received.
  • Q1-Q3 regulatory compliance monitoring and testing complete and reports distributed to appropriate parties.
  • Compliance Monitoring & Testing plans in place for Q4 and affected departments have been notified.
  • Annual required audits are completed or scheduled for BSA, ACH, and SAFE Act.
  • Annual required staff trainings are completed, documented or scheduled for BSA and SAFE Act.
  • Annual MLO registrations are renewed, documented and/or scheduled.
  • Annual exempt status designation completed, documented or scheduled for BSA (DOEP form).
  • Annual Privacy Notice distributed or scheduled to be distributed ( including online notices updated).
  • Compliance Risk Assessment reviewed, completed and/or scheduled.
  • Fair Lending Risk Assessment reviewed, completed and/or scheduled.
  • Identity Theft Red Flags audit complete and/or scheduled.
  • Cybersecurity Assessment/ audit complete and/or scheduled.
  • Internal Controls Audit/Risk Assessment reviewed, completed and/or scheduled.
  • Upcoming Change in Terms notifications scheduled for distribution.
  • Annual Escrow Statements are scheduled to go out within 30 days after the end of escrow account computation year (normally 12-month period).
  • MLA credit card disclosures, fees and rules effective this October are on track.
  • Annual Disaster Recovery Plan reviewed, test scheduled and/or planned.
  • Annual Regulation D reserve adjustments and reporting reviewed, completed and/or scheduled.
  • Record Retention Schedules have been reviewed, completed and/or scheduled.
  • Annual State Escheatment rules, procedures and forms have been reviewed, documented and/or scheduled.
  • Project deliverables for HMDA rules effective in 2018 are on track.


Regulatory Forecast: Important Upcoming Deadlines:

October, 2017

January, 2018

March, 2018

April, 2018

May, 2018

  • May 11th, 2018: Customer Due Diligence – CDD (FinCEN) – Effective date


If you need help staying on track or completing those deliverables, click here to see how we can help or contact CCUL Compliance at


Disclaimer: Views and opinions expressed in this article are those of the authors and should not be taken as legal advice, nor does this article entitle the reader to any services. The information contained herein is merely to provide League members with useful compliance information and serve as a reference for your own research. Although care has been taken to provide accurate information, the League is not engaged in rendering legal or tax advice. Credit unions are encouraged to seek appropriate qualified legal counsel for legal advice.

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