Compliance in Marketing, Advertising and Social Media
Intro: 0:00-1:20 Advertising Rules and Regulations: 1:20-7:15 Social Media Platform Rules: 7:15-34:35 Advertising/Social Media Best Practices: 34:35-56:46
Corporate Transparency Act and Beneficial Ownership Reporting Requirements
By: Michael Mulvey As of January 1, 2024, the Corporate Transparency Act (“CTA”) became effective. This legislation requires certain reporting requirements as part of the Anti-Money Laundering Act of 2020. To enforce these requirements, the Treasury Department’s Financial Crimes Enforcement Network (“FinCEN”) created a registry to receive all reportable information. This legislation intends to reduce […]
Financial Innovation – Loan Participation and Eligible Obligations Webinar
The NCUA’s new Financial Innovation Rule offers credit unions new and exciting lending opportunities. However, with these new and exciting opportunities come more responsibility on credit unions to reassess, strengthen and update their loan purchasing and lending policies and procedures. This webinar goes into detail about what changes were made to the NCUA’s loan participation […]
Third Party Relationships
Third party relationships can present great opportunities to credit unions to meet their strategic goals and to expand member services in an increasingly competitive marketplace. However, these opportunities must be properly evaluated, with risks assessed and adequately mitigated. This webinar reviews the NCUA’s supervisory guidance as to how credit unions should evaluate their third party […]
Corporate Separateness
By: Michael Mulvey mmulvey@cusolaw.com One of the benefits of forming a CUSO is the limited liability protection offered to a CUSO’s investor(s). In order to maintain this protection, the CUSO and investing credit union(s) must maintain corporate separateness. This means the two entities’ operations are separate and distinct from each other. The reason this […]
Crypto Rules
By: Michael Mulvey mmulvey@cusolaw.com For our blockchain or cryptocurrency enthusiasts out there: Following the downfall of FTX and subsequent hearings in December, Senators Elizabeth Warren and Roger Marshall introduced the Digital Asset Anti-Money Laundering Act authorizing rule making, risk-focused examination and review processes and reporting for federal agencies. SIL22D55 (senate.gov) Additionally, the New […]
NCUA Guidance Statement – Expansion of Permissible CUSO Activities and Associated Risks
By: Michael Mulvey mmulvey@cusolaw.com In November 2021, the NCUA expanded the lending capabilities of CUSOs. CUSOs can now engage in all types of lending permitted for federal credit unions. The NCUA recently released a letter to credit unions providing guidance on the CUSO lending rule now that the rule has been in effect for […]
Benefits of the Holding Company Structure
Leveraging the Profits Made by CUSOs The primary advantage to using a holding company CUSO is a consolidation of CUSO investments and leveraging the profitable CUSOs to make additional CUSO investments. A federally chartered credit union may only invest up to 1% of its assets in CUSOs in the aggregate. However, NCUA defines CUSO investment […]
NCUA CUSO Registration
As you know, part of forming a credit union service organization (“CUSO”) involves registering the company on the National Credit Union Administration’s (“NCUA”) CUSO Registry. Within sixty (60) days of the first credit union making an investment in the CUSO, the CUSO must register with the NCUA. The web-based registration process takes approximately fifteen minutes […]