Most Popular Compliance Content
UDAP vs. UDAAP
03/26/2023
Where does the CFPB’s authority come in when they determine something is “Abusive”?
Frequency of High-Risk Reviews
03/26/2023
How often do we need to review our high-risk customers?
How can automation improve my sanctions screening and management processes?
03/26/2023
How can automation improve my sanctions screening and management processes?
Loan policy exception examples
03/26/2023
What are some examples of loan policy exceptions?
Handling Deposits of MRB Staff
03/26/2023
A dispensary (Marijuana Related Business) just opened this month in town. We have two members (we are a credit union) that receive payroll from there (ACH). - Given their employer, is it illegal for them to bank with us? - Do we need to terminate our relationship with them? Our policy only states for MRB's that we would allow tier 2 and 3. Technically it is an individual, not a business though. Are we allowed to keep them? I know there are SARs we may have to file for MRB's (limited/terminated, etc.). If we keep thee depositors, do we have to file a SAR every 90 days on the individuals as long as they are employed at the dispensary? We understand there is a certain risk having them. There is really no guidance from FinCEN regarding employees of MRB's, just MRB's themselves. Any guidance would be greatly appreciated.