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Compliance Specific News & Resources for GoWest Credit Unions
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Compliance Newsletter

COMPLIANCE HEADLINES


Consumer Financial Protection Bureau (CFPB) 


Technical Correction and Update to the CFPB’s Credit Invisibles Estimate 


The CFPB released a widely cited report in 2015 that provided a benchmark for estimates of consumers with limited credit histories. More specifically, the report included estimates of the adult population in the United States who, in December 2010, did not have a credit record (“credit invisible”) or who had insufficient credit history to have a credit score (“stale unscored” and “insufficient unscored”). 


Subsequent analysis with updated data and a methodological correction reveals that the original estimate of credit invisibles should be roughly cut in half, with an almost commensurate increase in credit records that were unscored. The new data also show that the share of consumers with a scored credit record increased between 2010 and 2020. 


_________________________________________________________________________ 


Financial Crimes Enforcement Network (FinCEN) 


Financial Action Task Force Identifies Jurisdictions with Anti-Money Laundering, Countering the Financing of Terrorism, and Counter-Proliferation Finance Deficiencies  


At the conclusion of its plenary meeting, the Financial Action Task Force (FATF) updated its list of jurisdictions with strategic AML/CFT/CPF deficiencies. 


The FAFT added the British Virgin Islands and Bolivia to its list of Jurisdictions Under Increased Monitoring and removed Croatia, Mali, and Tanzania. 


The FAFT’s list of High-Risk Jurisdictions Subject to a Call for Action remains the same, with Iran, the Democratic People’s Republic of Korea (DPRK), and Myanmar (Burma) subject to calls for action. 



League InfoSight Highlight


Small Business Lending Rule Delayed Again 

  

Last week, the Consumer Financial Protection Bureau (CFPB) published an interim final rule extending the mandatory compliance dates once again for its small business lending data collection rule.  

  

The new mandatory compliance dates and first filing deadlines are as follows: 



With the extension of the mandatory compliance dates, the interim final rule also clarifies that a credit union may use any of the following for its determination period:  

  • 2022 and 2023, 

  • 2023 and 2024, or  

  • 2024 and 2025.  

  

The CFPB indicates that it plans to use this additional time to initiate new rulemaking, which we anticipate will make significant changes to the current small business lending data collection framework. The agency says that it “anticipates issuing a notice of proposed rulemaking as expeditiously as reasonably possible.” 




ARTICLES OF INTEREST


FinCEN Holds 62nd Bank Secrecy Act Advisory Group (BSAAG) Plenary 


FinCEN Releases Year in Review for Fiscal Year 2024 


Federal Reserve Board Announces that Reputational Risk Will No Longer Be a Component of Examination Programs in Its Supervision of Banks 


GENIUS, STABLE, and CLARITY Acts and State Laws 


FedNow Service Launches New Risk Mitigation Features and $1 Million Transaction Limit 


Section 1033 Update: The CFPB’s Open Banking Rule  


SCAM UPDATES


Yes, going to the DMV is the only way to avoid a REAL ID scam 


How to Avoid Work-From-Home Job Scams 


Don’t Pay For a Prize (Scam) 



COMPLIANCE CALENDAR

July 1, 2025: CFPB and FRB – Reg CC Threshold Adjustments 


July 14, 2025: Effective Date – FTC Negative Option Rule 


July 18, 2025: CFPB – Small Business Lending Data – ECOA 


Oct. 1, 2025: Quality Control Standards AVMs 


Oct. 1, 2025: CFPB: Overdraft Lending: Very Large Financial Institutions (Over $10 billion) 


Dec. 30, 2025: CFPB: Overdraft Lending: Very Large Financial Institutions (Over $10 billion)


Jan. 1, 2026: NCUA – Succession Planning Effective Date


March 1, 2026: CFPB: Residential Property Assessed Clean Energy Financing (Reg Z) 


April 1, 2026: Compliance Date – CFPB Personal Financial Data Rights for Credit Union’s Over $10 Billion in Assets 


June 19, 2026: NACHA – Fraud Return Reason Code


Dec. 12, 2026: NCUA Simplification of Share Insurance Effective Date 


TOOLS & RESOURCES

Effective Dates
Bulletins & Alerts
Webinar Calendar
AffirmX and GoWest Partnership

Q&A OF THE WEEK

Does our OREO policy have to be Board approved annually?


It would be best to have your board review the OREO policy annually. 

  

In Washington, the Division of Credit Unions recommends that, "A credit union that is managing a portfolio of OREO properties must have a board policy that assures that the board is regularly and competently informed of the nature and extend of the OREO holdings." 


One way to ensure that your board is up to speed on your OREO properties is to have the review and approve your policy annually. 


For your individualized login, select your state below. 

Arizona
Colorado
Idaho
Oregon
Washington
Wyoming

If you have questions about this communication, contact us at 800.546.4465 or via our shared email inbox at compliance@gowest.org.

Have a great weekend!

Your GoWest Compliance Team, 

David Curtis

CUCE

Director, Compliance Services
P: 206.340.4785

Tiarra Sanders-Hausa

NCCO

Manager, Compliance Services

P: 206.618.9302

Copyright © 2025 GoWest Credit Union Association. All Rights Reserved.

Mailing Address:
GoWest Credit Union Association, 18000 International Blvd Ste. 1102, SeaTac, WA 98188, United States
1.800.995.9064

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