MEMBER BENEFIT: NCUA Summary and FinCEN Summary + Comment Letter

Agency: National Credit Union Administration

Joint Policy Statement Summary: Prudent Commercial Real Estate Loan Accommodations and Workouts

The NCUA, FDIC, and OCC have published a joint policy statement on Prudent Commercial Real Estate Loan Accommodations and Workouts.  If finalized, the policy statement would address supervisory expectations related to commercial real estate risk management elements, loan classifications, regulatory reporting, and accounting considerations by updating existing interagency guidance, provide updated examples of classifications and income property valuation methodologies and address relevant accounting changes on loss estimates in Generally Accepted Accounting Principles (GAAP).

The deadline to submit a comment is October 3, 2022. The proposed rule may be read in its entirety here.

Click here to read the full NASCUS Summary (Member login required.)

Agency: Financial Crimes Enforcement Network (FinCEN)

FinCEN ANPRM: No-Action Letters

FinCEN has issued an advance notice of proposed rulemaking (ANPRM) soliciting public comment on questions relating to the implementation of a no-action letter process. The no-action letter process at FinCEN may affect or overlap with other forms of regulatory guidance and relief FinCEN currently offers, including administrative rules and exceptive or exemptive relief. Therefore, the ANPRM seeks input from the public on whether a no-action letter process should be implemented and, if so, how the no-action letter process should interact with those other forms of relief.

Click here to read the full NASCUS Summary (Member login required.)

Click here to read comments filed with FinCEN on August 5, 2022.