Compliance Calendar

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Click Here For The Complete 2019 Compliance Calendar

Click Here For The Complete 2018 Compliance Calendar

Click Here For Hawaii Important Reminders and Information

Click Here For Other Important Reminders and Information

Click Here For Disclaimer


UPCOMING COMPLIANCE EVENT DATES

February, 2019

March, 2019 April, 2019 May, 2019 June, 2019 July, 2019 August, 2019 September, 2019 October, 2019 November, 2019
  • November 11th, 2019: Veterans Day (observed) - Federal Holiday
  • November 28th, 2019: Thanksgiving Day - Federal Holiday
  • November 30th, 2019: New Employee Forms W-4 & HW-4
December, 2019 March, 2020 June, 2020 September, 2020

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Other Important Reminders and Information:

Annual Escrow Account Statement
The Annual Escrow Account Statement under the Real Estate Settlement Procedures Act (RESPA) is due to each member annually, within 30 days after the end of the escrow account computation year (the 12-month period beginning at the closing of the loan).

Privacy Notice
Credit unions must mail a privacy notice to all members and applicable non-members when there are any changes.

Bank Secrecy Act Exemption List

Elimination of designation and annual review for most Phase I customers. Credit unions are no longer required to file a “Designation of Exempt Person” ("DOEP") form for, or conduct an annual review of, customers who are other depository institutions operating in the United States, U.S. or State governments, or entities acting with governmental authority. The DOEP filing and annual review are still required for businesses listed on a major national stock exchange ("listed businesses"), non-listed businesses, and payroll customers.

Each credit union that wants to give a member (Customer) exempt status must make this designation separately and file the DOEP Form, and must verify, at least annually, the status of all exempt designations.

Credit Unions may designate an otherwise eligible non-listed business customer (Phase II) for exemption after the customer has within a year conducted five (5) or more reportable transactions in currency (previously, eight or more reportable transactions were required).

Waiting time for eligibility decreased:. Credit Unions may use a hybrid approach to designate an otherwise eligible customer for a Phase II exemption: The customer may be eligible for exemption after maintaining a transaction account for two months (previously twelve months were required); or, the customer may be eligible for exemption in less than two months if the bank conducts a risk-based analysis to form a reasonable belief that the customer has a legitimate business purpose for conducting frequent or regular large currency transactions.

Disaster Recovery Plan Test
NCUA guidelines recommend that federally insured credit unions test their disaster recovery plans at least once per year.

FinCEN 314(a) Requests/Filing
FinCEN receives requests from federal law enforcement and sends requests to designated contacts within financial institutions across the country. They typically are filed once every 2 weeks through a secured web site or by fax. The requests contain subject and business names, addresses, and as much identifying data as possible to assist the financial industry in searching their records.

The financial institutions must query their records for data matches, including accounts maintained by the named subject during the preceding 12 months and transactions conducted within the last 6 months. Financial institutions have 2 weeks from the transmission date of the request to respond to 314(a) requests. If the search does not uncover any matching of accounts or transactions, the financial institution is instructed not to reply to the 314(a) request.

IRS Tax Calendar
Credit unions required to make periodic payments to the IRS throughout the year should refer to the IRS Tax Calendar (Publication 509) which may be online or by phone at 1-800-829-3676.

NCUA Rules and Regulations Part 748 –
Security Program, Report of Crime and Catastrophic Act and Bank Secrecy Act Compliance Report

Credit unions must file with the NCUA Regional Director an annual statement certifying compliance with NCUA Rules and Regulations Part 748.1. The statement should be dated and signed by the president or other managing officer of the credit union. The statement should be contained on the OMB 3133-0053 - Report of Officials, which is submitted annually by credit unions within ten days of the election of officials.

OFAC Compliance
Credit unions are reminded to check the OFAC list of Specially Designated Nationals and blocked countries for any updates on a regular basis, either by accessing the list online or by calling OFAC’s fax-on-demand service at (202) 622-0077 or OFAC’s Compliance Hotline at 1-800-540-6322.

Report of Officials
This Report must be filed with the NCUA Regional Director No Later Than Ten (10) Days after the Election of Officials. One hardcopy of the Report or the use of one of the available electronic filing options outlined in the Report to Officials is required.   

Reserve and Reporting Requirements (Reg D)
Regulation D determines how much depository institutions must keep on hand either in vault cash, deposits at Federal Reserve Banks or in pass-through accounts at correspondent institutions as reserves. Click here for the InfoSight Reserve Requirements Topic.

SAFE Act - Annual Update
All institutions managing registered mortgage loan originators (MLOs) are required to renew their NMLS records each year. MLOs placed in an active status Registrations not renewed before year-end must be reactivated in order to be in an active status on the NMLS system. Click here for the instructions.

W-2 Update
Ask employees whose withholding allowances will be different in the following year to fill out a new Form W-4 by February 15.
IRS Publication 15 (Circular E) Employer's Tax Guide.

W-4 Update
Before December 1st each year, request a new "Employees' Withholding Allowance Certificate" (Form W-4) from each employee who claimed total exemption from withholding during the current year. On the following  February 16, the credit union is required to begin withholding income tax from the pay of any employee claiming exemption and has not provided an updated W-4 Form. IRS Publication 15 (Circular E) Employer's Tax Guide.

W-5 Earned Income Credit
During November, each eligible employee to receive advance payments of the earned income credit during the following year must complete IRS Form W-5. A new Form W-5 must be filled out each year before any payments are made. The current revision of Form W-5 is available on the IRS website.
IRS Publication 15 (Circular E) Employer's Tax Guide.

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Hawaii Other Important Reminders and Information:

Within 10 days after your annual meeting:
Send the NCUA Regional Office and HCUL the “List of Officials” (NCUA 4501).


*REMINDER: On a quarterly basis each credit union is required to provide to the Child Support Enforcement Agency (CSEA), the name, record address, social security number, or other tax payers identification number and other identifying information for each non-custodial parent who maintains an account at your credit union and who owes past due support.

If your credit union changed data processors during the year and have not contacted the State of Hawaii Child Enforcement Agency and you are not receiving a data match file from the State, you are in violation of HRS 576D-15.  For additional information and  office locations:

CSEA Offices Walk-in/Telephone Hours:
9:00 a.m. to 3:00 p.m. Monday through Friday, except State Holidays.

Customer Service Telephone & Fax:
O’ahu phone: 692-8265 fax number: 692-7060

Maui phone: 243-5241 fax number: 243-5161
Kaua’i phone: 241-7112 fax number: 241-3816
Hawai’i (Hilo) phone: 933-0644 fax number: 933-0300

Moloka’i, Lana’i, and Mainland customers may call toll-free at (888) 317-9081 OR

Email: For general questions or concerns, you can email CSEA using this form.

Disclaimer

**THIS LIST IS SUBJECT TO CHANGE AS FEDERAL AND STATE LAWS OR REGULATIONS CHANGE. IF YOU ARE AWARE OF OTHER FILING DEADLINES AFFECTING CREDIT UNIONS THAT ARE NOT LISTED HERE, PLEASE CONTACT THE LEAGUE’S LEGISLATIVE & REGULATORY AFFAIRS DEPARTMENT AT 941.0556 OR 1.888.331.5646.

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