NCUA Joins With Other Agencies in Statement to Clarify BOI Rules; Offers Two CECL-Related Updates

ALEXANDRIA, Va. – NCUA has joined with the  Financial Crimes Enforcement Network (FinCEN) and other agencies in issuing a joint statement designed to provide clarity for banks regarding FinCEN’s final rule on access to beneficial ownership information.

In the statement, the agencies explain that financial institutions subject to customer due diligence requirements are one category of authorized recipients to access beneficial ownership information.

No New Requirements

“The Access Rule does not create new regulatory requirements or supervisory expectations for banks, unless banks decide to access and use beneficial ownership information,” the statement reads. “Any access and use of beneficial ownership information must comply with the Corporate Transparency Act and FinCEN’s Access Rule requirements. As such, FinCEN’s Access Rule does not necessitate changes to Bank Secrecy Act/anti-money laundering compliance programs designed to comply with the existing Customer Due Diligence rule and other existing BSA requirements.”

In addition to FinCEN and NCUA, the statement was also joined by the Federal reserve, FDIC, the Office of the Comptroller of the Currency, and state bank and credit union regulators.

Additional information can be found here.

Updated CECL Tool

Separately, NCUA announced two actions related to CECL.

The agency has released the December 2023 update of its Simplified CECL Tool. The update includes the latest life-of-loan, or Weighted Average Remaining Maturity, and other enhancements, it said.

The agency noted that for most credit unions, CECL became effective Jan. 1, 2023. For credit unions that are currently using the Simplified CECL Tool, NCUA said it provides the September 2023 release to determine the credit loss expense, or provision for credit losses, for the quarter that ends Dec. 31, 2023.

For credit unions that adopted CECL in the fourth quarter of 2023, the December 2023 Call Report will include the day-one adjustment to undivided earnings and the credit loss expense since the date of CECL adoption.

For additional info, NCUA is directing credit unions to its Simplified CECL Tool page.

Technical Correction Published

Separately, NCUA has published a technical correction related to the calculation of the current expected credit loss (CECL) transition amount in its regulations.

The agency said credit unions that adopted the CECL accounting standard in 2023 should use the method described below to calculate and report on the Call Report their CECL transition amount.

NCUA said credit unions should ensure computation alignment with the transition rule’s intent by calculating the CECL transition amount for months four through 12 as the difference between:

  • The credit union's retained earnings as of the beginning of the fiscal year in which the credit union adopts CECL, adjusted for any restatement of the initial CECL adoption amount
  • The credit union's retained earnings as of the closing of the fiscal year immediately before the credit union’s adoption of CECL

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