The bank, which merged with Mellon Financial in 2007 and is known as Bank of New York Mellon, was required to increase its staff and revamp its internal controls following the Fed's investigation, which revealed problems in the way the bank reported suspicious activities and due diligence regarding customer risk.
Federal credit unions can't offer investment advice, but they can establish a shared employee arrangement with a third-party registered investment adviser, according to a legal opinion letter by NCUA Associate General Counsel Sheila Albin.
She noted that firms and individuals offering advisory account services must be registered as Registered Investment Advisers.
In this type of arrangement, the employee is acting in a dual capacity as an employee of the FCU and the third-party investment adviser. A shared employee may provide investment advice when doing so only on behalf of and under the control of the third-party RIA but not in the employee's capacity as an FCU employee.