ARLINGTON, Va.—What does NCUA's proposed Interpretive Ruling and Policy Statement (IRPS) related to a section of the Federal Credit Union Act regarding convicted criminals mean for credit unions?
NAFCU Regulatory Compliance Specialist Alma Calcano credit unions need to understand the new IRPS:
- Expands the current de minimis exception to include additional offenses
- Clarifies that all of the sentencing requirements associated with a conviction or conditions imposed by the pretrial diversion or similar program, including, but not limited to, imprisonment, fines, condition of rehabilitation, and probation requirements, must be completed before the board will deliberate a consent application
- Implements a new age-based exception to the filing requirement
- Expands the exception to include convictions or program entries for insufficient funds checks of aggregate moderate value, small dollar simple theft, false identification, and simple misdemeanor drug possession
Reduced Offenses
These changes, Calcano noted, would "reduce the number of offenses that would require an application to the board…and expand the pool of applicants credit unions can consider for employment."
The proposal's impact on credit unions' bond coverage against dishonesty or fraud by employees is also explained by Calcano in the blog post here.