Compliance Q&A: OFAC, FCRA, and the SAFE Act

When must mortgage loan originators be fingerprinted?

August 24, 2011
KEYWORDS credit , regulation
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Q Does a credit union need to file the Office of Foreign Assets Control’s (OFAC) Annual Report of Blocked Property if it has had no “hits” on the Specially Designated Nationals (SDN) and Blocked Persons List in the past year?

A OFAC requires credit unions to block property (i.e., freeze funds) involving blocked countries, entities, and individuals that appear on the SDN List.

Credit unions must report all blockings to OFAC within 10 business days of occurrence, and file a comprehensive annual report (Form TDF 90-22.50) by Sept. 30 each year of all blocked property held as of June 30.

There’s no need to file the annual report if the credit union has had no “hits” on the SDN List and holds no blocked property.

Next: FCRA opt-out regs

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