On Feb. 8, 2016, the Federal Register comment period closed for the NCUA's proposed reform of the field of membership regulations. Credit unions considering an expanded FOM must also consider the impact of an expanded FOM on their existing Bank Secrecy Act/Anti-Money Laundering programs. A more expansive FOM would create a more expansive BSA/AML burden.
An expanded FOM will potentially impact a credit union's entire BSA/AML program, but areas with the greatest impact are likely to be the customer identification program, the independent testing requirements, and training and enforcement risk.
In addition, on July 30, 2014, the Financial Crimes Enforcement Network, a key BSA/AML regulator, issued a Notice of Proposed Rulemaking to clarify and strengthen customer due diligence requirements as a fifth pillar under BSA/AML compliance programs. Under the proposed rule, financial institutions would be required for the first time to identify and collect information on the beneficial owners of their legal entity customers and treat CDD as a pillar.
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