NAFCU shares concerns on customer due diligence ahead of subcommittee hearing

WASHINGTON, DC (April 27, 2018) — National Association of Federally-Insured Credit Unions (NAFCU) Vice President Brad Thaler today sent a letter to the House Financial Services Committee, Subcommittee on Financial Institutions and Consumer Credit Chairman Blaine Luetkemeyer, R-Mo., and Ranking Member Lacy Clay, D-Mo., highlighting areas of uncertainty within the Financial Crimes Enforcement Network’s (FinCEN) customer due diligence (CDD) rule. NAFCU highlighted how the rule – with a mandatory compliance date of May 11 – is impacting the credit union industry.

In the letter, Thaler explained that, even though FinCEN has provided guidance documents, more guidance is needed from FinCEN on this rule and how certain areas within the rule could bring a “lack of uniformity” in how regulators evaluate compliance.

“NAFCU supports recent legislative efforts to help facilitate more coordination between state agencies, law enforcement, and credit unions by ensuring that credit unions have access to beneficial ownership information collected by states, relating to corporations or limited liability companies formed under state laws,” Thaler wrote.

The final CDD rule requires credit unions and other covered institutions to identify the beneficial owners (25 percent or higher ownership) who control legal entities who open accounts. The rule also amends the anti-money laundering program requirements to include risk-based procedures to conduct ongoing member due diligence.

On Monday, NAFCU met with FinCEN to share the credit union perspective on regulations under the Bank Secrecy Act (BSA) and impending CDD rules in an effort to improve the industry’s regulatory environment.

For full text of the letter, please click here.


he National Association of Federally-Insured Credit Unions is the only national trade association focusing exclusively on federal issues affecting the nation’s federally-insured credit unions. NAFCU membership is direct and provides credit unions with the best in federal advocacy, education and compliance assistance. For more information on NAFCU, go to or @NAFCU on Twitter.


Jacqueline Ramsay

Bobby Grant

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