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Compliance Specific News & Resources for GoWest Credit Unions
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Compliance Newsletter

COMPLIANCE HEADLINES



National Credit Union Administration (NCUA) 


NCUA Seeks Credit Union Input at Virtual Town Hall on Sept. 9 


The NCUA will host a Virtual Strategic Plan Town Hall on Tuesday, Sept. 9 starting at 2 p.m. ET. The event invites credit union industry stakeholders to provide input on the next NCUA Strategic Plan and the upcoming priorities of the agency. 


The NCUA Strategic Plan Town Hall will be a moderated virtual discussion open to credit unions, credit union service organizations (CUSOs), leagues, and industry trades. 


Participants are required to register in advance and are encouraged to submit Strategic Plan-related discussion topics via the town hall registration form. 


U.S. Court of Appeals Grants Stay and Sets Expedited Briefing Schedule for Harper-Otsuka Challenge to NCUA Dismissal 


The U.S. Court of Appeals for the D.C. District sets a fast track briefing schedule in the dismissal of NCUA board members Todd Harper and Tanya Otsuka. In addition, the court order grants the administration’s emergency motion for stay pending appeal, which will keep both off the board until the litigation is resolved. 


The administration’s next brief is due Sept. 12, with Harper and Otsuka’s reply brief to follow by Oct. 3, and the government’s reply due Oct. 17. The clerk of the court was directed to schedule the case for “the first appropriate date following the conclusion of the briefing,” with the parties to be informed of oral argument dates later. 


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Consumer Financial Protection Bureau (CFPB) 


Advance Notice of Proposed Rulemaking for Open Banking Rule 


The CFPB published an advance notice of proposed rulemaking in the Federal Register seeking input on four issues related to the implementation of section 1033 of the Dodd-Frank Act. 


The questions the CFPB is seeking comment on are: 

  • Scope of who may make a request on behalf of a consumer; 

  • Defraying of costs in exercising rights under section 1033; 

  • Information security concerns in the exercise of section 1033 rights; and 

  • Privacy concerns in the exercise of section 1033 rights. 


The CFPB is also seeking comment on the appropriateness of the compliance dates in the final rule and what extension may be appropriate. 


Comments are due by Oct. 21, 2025. 

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Financial Crimes Enforcement Network (FinCEN) 


Treasury Extends Effective Dates of Orders Issued Under New Authority to Counter Fentanyl 


FinCEN extended the effective dates of orders prohibiting certain transmittal of funds involving three Mexico-based financial institutions. Covered financial institutions will now have until Oct. 20, 2025, to implement the orders prohibiting certain transmittal of funds involving CIBanco S.A., Institución de Banca Multiple (CIBanco), Intercam Banco S.A., Institución de Banca Multiple (Intercam), and Vector Casa de Bolsa, S.A. de C.V. (Vector), each of which FinCEN found to be of primary money laundering concern in connection with illicit opioid trafficking pursuant to the Fentanyl Sanctions Act and the FEND Off Fentanyl Act. 


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U.S. Department of Treasury (Treasury) 


Treasury Issues Request for Comment Related to the Guiding and Establishing National Innovation for U.S. Stablecoins (GENIUS) Act 


The Treasury issued a Request for Comment to fulfill the Treasury’s obligation under the GENIUS Act as part of the process to create a comprehensive regulatory framework for stablecoin issuers in the United States. 


The GENIUS Act lists four specific technologies on which Treasury should seek comment:  


  • application program interfaces (APIs);  

  • artificial intelligence (AI);  

  • digital identity verification; and 

  • use of blockchain technology and monitoring. 


Consistent with the GENIUS Act, when conducting research on these and other innovative or novel methods, techniques, or strategies, Treasury will evaluate and consider:  


  • improvements in the ability of financial institutions to detect illicit activity involving digital assets;  

  • costs to regulated financial institutions;  

  • the amount and sensitivity of information that is collected or reviewed;  

  • privacy risk associated with the information that is collected or reviewed;  

  • operational challenges and efficiency considerations;  

  • cybersecurity risks; and 

  • effectiveness of the methods, techniques, or strategies at mitigating illicit finance. 


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Internal Revenue Service (IRS) 


IRS Issued FAQs to Address the Accelerated Termination of Several Energy Provisions Under the OBBBA 


The IRS released FAQs to provide guidance on several energy credits and deductions that are expiring under OBBB and their termination dates. 


The FAQs also provide clarification on the availability of the new clean vehicle credit, the energy efficient home improvement credit, and the residential clean energy credit, among others. 

   

League InfoSight Highlight


The Board of Directors and Credit Union Policies 

  

The board of directors, in exercising general oversight of the credit union, should enact policies that guide the institution’s day-to-day operations. Some policies are specifically required by the Federal Credit Union Act or the NCUA’s regulations. Other policies may be recommended based on the credit union’s product and service offerings, financial condition, or field of membership.  

  

The NCUA offers guidance on required policies and review timeframes here. The agency identifies 38 policies that are either expressly required or highly recommended, and the cadence with which those policies should be reviewed.  

  

CU Policy Pro is here to help! This online library offers over 200 policy and procedure templates customizable to your credit union. Documents related to administration, credit union operations, accounting, security, asset/liability management, investment, lending, and record retention are available. The CU Policy Pro guidance document identifies which policies are mandatory, which are recommended, and which are optional.  

  

If you’d like to learn more about how CU Policy Pro can help your credit union, please visit www.infosight360.com or e-mail us at 360support@infosight360.com





ARTICLES OF INTEREST


Executive Order on Fair Banking 


Unauthorized Transactions and Error Resolution Procedures 


SCAM UPDATES


U.S. Department of Labor Helps Recover $520 Million in Suspected Fraudulent Pandemic-Era Unemployment Insurance Payments 


Moving this summer? Watch for rental scams  


Five Ways to Help You Cut Down on Unwanted Calls 



COMPLIANCE CALENDAR

Sept. 4, 2025: CFPB Cognitive Decline and Financial Exploitation in Older Age Webinar 


Sept. 9, 2025: NCUA Virtual Strategic Plan Town Hall 


Sept. 18, 2025: FDIC, FRB, Treasury, OCC – Request for Comment on ways the agencies can take action collectively or to help consumers, businesses, and financial institutions mitigate check, automated clearing house (ACH), wire, and instant payments fraud.


Sept. 30, 2025: Federal Benefit Payment Checks No Longer Issued 


Oct. 1, 2025: Quality Control Standards AVMs 


Oct. 21, 2025: CFPB Comments Due ANPR on Open Banking Rule


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) 


March 20, 2026: NACHA Risk Management Topics – Company Entry Descriptions 


March 20, 2026: NACHA Risk Management Topics - (Fraud Monitoring Phase 1) 


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


July 1, 2026: CFPB – Small Business Lending Data – ECOA


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

A member gave one of the tellers a photocopy of a check and claims that the original check is lost. Should we honor this photocopy? 


No. The credit union should not cash the photocopy since the photocopy is not the legal equivalent of a check. Accepting a photocopy of a check as a valid check and cashing it could expose the credit union to liability and a potential lawsuit by the member.  



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

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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