Bi-Monthly New & Updated ii Releases

ii Release No. 0130 – Tax Reporting Requirements, has been revised to add information on Wisconsin sales and use tax obligations for credit unions.

ii Release No. 0012 – Custodial Accounts Under UTMA & Services for Minors, has been updated to clarify that Wisconsin’s version of the Uniform Transfers to Minors Act (which is found in subchapter VII of Chap. 54 in the Wisconsin Statutes) does not provide for POD beneficiaries on custodial accounts. That’s why The League’s custodial account card does not include space to designate a POD beneficiary. If the minor dies, the custodian must turn the funds over to the minor’s estate. The Wisconsin Statutes say that this must be done “in an appropriate manner,” which may require issuing a check payable to the minor’s estate, if a probate estate is established, or to an heir of the minor who presents a Transfer by Affidavit form.

ii Release No. B057 – Homeowners Protection Act, was updated to add links to help CFPB and NCUA resources on the Homeowners Protection Act, which permits a borrower to cancel or requires termination of private mortgage insurance (PMI) when the level of equity in the home reaches a certain level.

ii Release No. 0181 – Interest Rate Risk Policy and Program, has been updated to reflect that the NCUA’s regulations require an interest rate risk policy for all federally insured credit unions with assets of more than $50 million. We want to remind credit unions that this policy must be evaluated at least annually. The ii Release also now includes updated links to current NCUA guidance on IRR.

ii Release No. 0155 – NCUA Guidelines for Safeguarding Member Information, Responding to Unauthorized Access and Reporting Cyber Incidents, to add details about NCUA catastrophic act preparedness guidelines. Appendix B to Part 749 of the NCUA Rules and Regulations recommends that all credit unions develop a program to prepare for a catastrophic act. The program should be developed with oversight and approval of the board of directors, and it should be based on the credit union’s assessment of risks. The program should address five listed elements, including: “Internal controls for reviewing the plan at least annually and for revising the plan as circumstances warrant, for example, to address changes in the credit union’s operations” and “annual testing.”

ii Release No. B041 – Reg. B – Equal Credit Opportunity, has been revised to clarify Reg. B’s adverse action notice timing rules, which say that if a credit union takes adverse action on an existing account, it must provide an adverse action notice within 30 days after taking the action. 

ii Release No. 0132 – Reg. D – Reserve Requirements of Depository Institutions, has been updated to remove obsolete material related to Federal Reserve Board reporting and reserve requirements.
 

• Obtaining signatures on new Oath of Office forms (for state-chartered credit unions); and 
• Ensuring that a Credit Union Profile, NCUA Form 4501 or its equivalent, is filed. This must be done within 10 days after an election or appointment of senior management or volunteer officials or within 30 days of any change of the information in the profile.

ii Release No. 0130 – Tax Reporting Requirements, has been renamed from Annual Reporting Deadlines and significantly revised and shortened. The ii Release summarizes numerous state and federal tax reporting requirements that may apply to credit unions. It also provides links to numerous resources that can help your staff understand their tax reporting obligations. The ii Release no longer summarizes lengthy passages of materials from federal and state tax forms, instructions, or guides. Rather, it briefly recaps what those publications cover and provides links that can be used to review the publications for needed details. Material that summarized other (non-tax-related) compliance obligations has been removed and will be included in a new ii Release, to be titled “Recurring Compliance Obligations.”

ii Release No. 0007 – Wisconsin Unclaimed Property Law, has been updated to include information about the Wisconsin Department of Revenue’s unclaimed property voluntary disclosure program, which lets credit unions (and other businesses and organizations) that have not complied with the state’s unclaimed property laws voluntarily come forward to report and remit unclaimed property without penalties. The program had been temporary, but was made permanent in 2024.

ii Release No. 0100 – Reg. CC – Expedited Funds Availability, has been revised to update a Federal Reserve example of how the “large-dollar exception” applies. That is one of the exceptions that allows credit unions and other financial institutions to exceed the maximum hold periods in their availability schedules. An example is now given to show how the Reg. CC rules’ large-dollar exception will apply after July 1, 2025, when revised Reg. CC dollar thresholds take effect, as described in this Compliance Courier. 

ii Release No. 0148 – OFAC Compliance, has been updated to reflect OFAC’s new 10-year record retention requirement (an increase from five years previously), which takes effect on March 12. For details, please see this Compliance Courier.

ii Release No. B059 – Child Support Enforcement: Lien Docket, has been updated to add information about the priority of child support liens and the possibility of the Department of Children and Families or a local child support agency agreeing to subordinate its lien to a credit union’s lien on collateral.

ii Release No. 0175 – Electronic Signatures and Records, has been revised to clarify that Article 9 of the Uniform Commercial Code has its own provisions that allow for electronic signatures on documents like security agreements.

ii Release No. B009 – Mechanic’s Liens; Vehicle Towing & Storage Liens, has been revised to include updated dollar thresholds for mechanic’s liens and vehicle towing & storage liens for 2025. The new amounts apply for work commenced on or after Jan. 1.

ii Release No. 0180 – Duties, Liabilities & Protections of Credit Union Directors, has been updated to summarize the NCUA’s new rule, which takes effect Jan. 1, 2026 that will require the boards of all federally insured credit unions to establish written succession plans for key positions. The rule will apply to all Wisconsin credit unions (since they must be federally insured), regardless of asset size. For details, please see this Compliance Courier.

ii Release No. B017 – Reg. C – Home Mortgage Disclosure Act, and
ii Release No. B068 – Reg. Z – Higher-Priced Mortgage Loans, have been updated to reflect annual CFPB Adjustments to the HMDA reporting and HPML escrow thresholds, as explained in this Compliance Courier.