![]() Webinar – New Cyber Incident Reporting Rule Credit unions can get valuable information on the National Credit Union Administration’s new cyber incident notifications rule on an August 2 webinar hosted by the agency. Registration for this webinar is now open. This free webinar will discuss:
As a reminder, earlier this year the NCUA finalized a rule to require a federally insured credit unions that experience a reportable cyber incident to report the incident to the NCUA as soon as possible and no later than 72 hours after the FICU reasonably believes that it has experienced a reportable cyber incident. This final rule is effective September 1, 2023 and can be found here. Trusted Contact Resources As discussed previously, the National Credit Union Administration (NCUA) provided information in a recent consumer tip – protect your money with a trusted contact. A short video, aimed at educating members, can be found here. As discussed in the consumer tip, choosing a trusted contact can help the member prevent fraud and scams without giving up control of their finances. In addition to the Trusted Contact tip, the NCUA has a number of other resources available to help protect older adults, which can be found here. NCUA has also provided guidance for credit unions on how they can help fight elder financial exploitation; consider sharing the poster found at the previous link with all staff. In response to requests from credit unions seeking more guidance on Trusted Contacts, the third quarter content update to CU PolicyPro addresses this topic in updated Policy 2245 to include Trusted Contact Person information. Also, new content was added with the new Trusted Contact Person Procedures (2245.10), Trusted Contact Person Model Script (2245.11), and Trusted Contact Information and Authorization Form. In addition to the CU PolicyPro updates, a Trusted Contact Person Toolkit has been added to InfoSight and is available free of charge for affiliated credit unions. Credit unions can read more about this collaborative initiative and the availability of these resources here. Scams and Frauds The Federal Trade Commission (FTC) recently posted about several scams that are worth highlighting again – also, these consumer alerts from the FTC often come with social media graphics that can be helpful in educating your membership about these scams as we all work together to prevent the scams and protect the consumers. Cryptocurrency – as explained by the FTC, scammers are targeting people with limited knowledge about cryptocurrency. FTC offers these tips - Don’t trust people who make big promises or guarantees. Only scammers promise “no risk” and guarantee high returns. Research the company or cryptocurrency platform. Search online for the company or crypto platform name, plus “review,” “scam,” or “complaint” to see what people say. Investment Opportunity - Investment scams create the impression that you can "make lots of money" with "little to no risk." They often start on social media, online dating apps, or from an unexpected text, email, or call. Tip - Don’t accept any unsolicited offers. If you get an out-of-the-blue call, text, or email about “an amazing investment opportunity,” it’s a scam. Walk away. Job Scams - Scammers advertise jobs the same way honest employers do — online (in ads, on job sites, and social media), in newspapers, and sometimes on TV and radio. Tip - Don't pay for the promise of a job. Honest employers, including the federal government, will never ask you to pay to get a job. Anyone who does is a scammer. Also - Never bank on a “cleared” check. No honest potential employer will ever send you a check to deposit and then tell you to send on part of the money, or buy gift cards with it. That’s a fake check scam. The check will bounce, and the bank will want you to repay the amount of the fake check. CU PolicyPro Update CU PolicyPro 3rd Quarter Content Update is here. In addition to five policy updates, new content has been added relating to Trust Contact Person Procedures and Artificial Intelligence (AI) Usage. As a reminder – these updates are only made to the “model” policies and the credit union’s adopted policies. Please review the July 2023 Overview Document and/or the redlined documents related to this update (these can be found in the Resources area of CU PolicyPro under Content Update Archives) and for each policy decide if you want to - Do nothing and leave your policy as is (usually only if the update does not apply to your credit union, or you are not currently using the policy). Or remove the policy from your CU Policies Manual and bring in the updated policy in its entirety (usually if your CU Policies Manual version has little or no customization, or if the updates were very extensive and it would be easier to start with the updated content and re-customize for your credit union). Another option is to use the redlined version as a guide and manually incorporate the updates into your CU Policies Manual version (usually if the updates were very minor, or if your CU Policies Manual version is heavily customized and it would be less work to manually add the updates rather than re-customize the policy). The following updates are included in this Q3 content update. 2245 – Elder and Vulnerable Adult Protections. This policy was updated to include content regarding the establishment of a trusted contact. Credit unions who are interested in providing this option to their members should implement these changes and should also utilize the Trusted Contact Procedures (2245.10), Trusted Contact Model Script (2245.11), and the Trusted Contact Information and Authorization Form (this form is found in the Resources area of CU PolicyPro under the Sample Forms and Documents folder). 4500 – Artificial Intelligence (AI) Usage This model policy was created to create parameters for the credit union when implementing artificial intelligence (AI). While no official guidance has yet been released by the NCUA (including the actual requirement for a policy), the Agencies have issued a Request for Information and Comment. 7315 – Commercial Real Estate Loan Workouts and Modifications. This policy was updated to comply with the new Joint Interagency Statement regarding Commercial Real Estate Loan Accommodations and Workouts. (Required) 7715 – Allowance for Credit Losses. This Policy was updated to reflect the minor changes made in the NCUA’s Update to Interagency Policy Statement on Allowance for Credit Losses. Many significant changes with the elimination of the recognition and measurement accounting guidance for TDRs were already implemented and reflected within Policy 3170 as part of the January 2023 update. Minor changes were required, including the citation reference the previous guidance. 7715.10 – Allowance for Credit Losses Methodology. Similar to the 7715 Policy, the methodology was updated to capture the changes made in the NCUA’s Update to Interagency Policy Statement on Allowance for Credit Losses. 10009 – Records Retention Table 9: personnel and Employment Records. This table was updated to amend the retention requirement for Polygraph Tests, which was previously listed incorrectly under Injury Reports. DakCU members may contact Amy Kleinschmit with any compliance related questions. Comments are closed.
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