If you were hoping for a breather, let me be the first to apologize for your dashed hopes. From enforcement policy shifts to leadership changes at NY DFS, the regulators have kept things moving. Here’s what credit unions need to know—and how these updates might reshape the compliance landscape heading into Q4.
NCUA Doubles Down on “No Regulation-by-Enforcement” Policy
- Chairman Kyle Hauptman issued a formal policy statement reaffirming that enforcement should focus on “clear and significant violations” of existing law
- The policy reinforces that examination findings should be based on established rules, not examiner interpretation or agency wish lists
- This means no more surprise policy changes buried in enforcement actions; a welcome relief for credit unions tired of regulatory whiplash
Multi-Agency SAR Guidance Gets an FAQ Refresh
- NCUA, FDIC, Federal Reserve, OCC, and FinCEN released updated FAQs on Suspicious Activity Reports and AML/CFT requirements
- The four FAQs clarify requirements relating to structuring, continuing activity reviews, and decisions not to file a SAR
CFPB Extends Small Business Lending Data Compliance Dates
- The CFPB finalized its rule extending Section 1071 compliance dates
- The new timelines are: Tier 1—July 1, 2026, with first filing due July 1, 2027; Tier 2—January 1, 2027, with first filing due June 1, 2028; and Tier 3—October 1, 2027, with first filing due June 1, 2028.
- Lenders are in Tier 1 if they originated at least 2,500 covered loans in the preceding two years, Tier 2 if they originated at least 500 covered loans, and Tier 3 if they originated at least 100 covered loans.
- Lenders can choose their origination look back period: 2022-2023; 2023-2024; or 2024-2025.
New York Department of Financial Services Gets New Leadership
- On October 18, Superintendent Adrienne Harris steps down after four years leading the department
- Kaitlin Asrow, current Executive Deputy Superintendent of Research & Innovation, becomes Acting Superintendent
- Expect NYDFS to maintain its tech-forward regulatory approach; Asrow’s background in fintech and virtual currency regulation suggests continuity in the department’s innovation initiatives.
Looking Ahead
Keep your calendars marked for October 21, 2025, when the Federal Reserve hosts its “Payments Innovation Conference.” Expect discussions on stablecoin use cases, AI in payments, and the convergence of traditional and decentralized finance. It’s the kind of forward-looking conversation that could signal where regulatory attention heads next. You can see the live broadcast at https://www.federalreserve.gov/default.htm or The Fed’s YouTube channel.
Let’s Make This Useful
I want this blog to be as relevant as possible to the people reading it. So:
- Got a topic you’d like me to break down?
- Burning desire to know more about that headline you read the other day?
- Have an industry-related question you want addressed?
Reach out to me at jeremy.newman@nycua.org. Let’s talk.
Until Next Time
From the big picture to the fine print, we’ve got you covered. Thanks for reading, and CU in the next post.