FinCEN Not Issuing Fines or Penalties in Connection with Beneficial Ownership Information Reporting Deadlines: On February 27, 2025, FinCEN announced that it will not issue any fines or penalties or take any other enforcement actions against any companies based on any failure to file or update beneficial ownership information (BOI) reports pursuant to the Corporate Transparency Act by the current deadlines. 

Department of Commerce ATM and ITM Fraud Recommendations: The Minnesota Department of Commerce’s Director of Credit Unions, Aeton de Long-Hersh, issued recommendations for credit unions regarding recent ATM and ITM robberies.

DOJ Data Security Rule and Credit Unions: On December 27, 2024, the Department of Justice (DOJ) issued a final rule reflecting executive order 14117 that aims to prevent access to Americans’ bulk sensitive personal data and U.S. government-related data by “countries of concern,” including China, Russia, Cuba, Iran, North Korea and Venezuela. 

On February 3, the newly appointed acting director of the Consumer Financial Protection Bureau (CFPB), Scott Bessent, announced the immediate cease of the Bureau’s regulatory operations and activities.​

​Department of Commerce ATM Reminder: The Minnesota Department of Commerce’s Director of Credit Unions, Aeton de Long-Hersh, issued a reminder for credit unions to follow regarding ATM preventive security measures against break-ins. 

OFAC Transaction Record Retention Period Extended: The Office of Foreign Asset Control (OFAC) published its interim final rule extending recordkeeping requirements for certain transactions from five to 10 years effective March 12, 2025.
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​FTC CARS Rule Overturned: The Federal Trade Commission (FTC) Combating Auto Retail Scams (CARS) rule effective date, which was paused due to litigation in 2024, has now been overturned by the Fifth Circuit Court of Appeals for not providing proper notice of rulemaking in a 2-1 split decision.

Open Banking Section 1033 Updates: Effective January 17, changes to the Open Banking system were published in the Federal Register outlining coverage under the new Open Banking system in Title 12 Chapter X Part 1033 Subpart A with coverage of data providers such as credit unions by determining SBA size standard. 

Julie Cayse Named NCUA Western Region Director: The National Credit Union Administration named Julie Cayse as the new regional director, Western Region, effective January 12. 

NCUA Updates Cyber Incident Reporting Guidance: On January 13, the National Credit Union Administration (NCUA) issued an update to its Letter to Credit Unions 23-CU-07 on Cyber Incident Notification Requirements. 

2025 NCUA Examination Priorities: The NCUA’s January letter to credit unions outlined examiner supervisory priorities to protect credit union members, credit unions and the NCUA Share Insurance Fund from risk. 

​CFPB Proposed Rule Updates: The Consumer Financial Protection Bureau (CFPB) has taken multiple actions on proposed rules and notices for public comment this month.​

​Today, the Minnesota Credit Union Network (MnCUN) joined 17 credit union leagues and associations in filing an amicus brief in support of America’s Credit Unions’ recent federal lawsuit challenging the Consumer Financial Protection Bureau’s (CFPB) final rule that sets a fee cap on overdraft protection programs. Collectively, leagues and associations that filed the amicus brief represent 3,237 credit unions and 105,000,000 credit union members.

The amicus brief highlights the significance of credit unions’ unique member-owner relationship that is fundamental to their mission of serving their communities. The CFPB’s final rule focuses on calculating costs and assessing fees, failing to account for credit unions’ unique capital and operational realities. The final rule was developed with data from five financial institutions that does not represent the diversity of the financial services industry.

“Many consumers chose overdraft protections as a financial service and credit unions are providing that option transparently in response to the needs of their members. Existing regulations ensure overdraft protection products do not cause unnecessary consumer harm," said MnCUN President and CEO Mara Humphrey. “The CFPB’s finalized rule disregards decades of precedent set by the Federal Reserve Board and they have overstepped their statutory authority by classifying overdraft services as credit under the Truth in Lending Act, completely failing to consider the broader economic and operational impacts of the rule. Ultimately, the rule threatens to reduce access to financial services in rural areas and underserved communities which directly goes against the mission of credit unions.”

Contact MnCUN Chief Advocacy Officer Ryan Smith with questions.

Minn. Department of Commerce Updates for 2025: The Minnesota Department of Commerce advises credit unions to create a system for administering employees system access rights, regular reviews of employee access levels, and controls over privileged users/accounts. 

​NCUA Guidance on OD and NSF Fees: On December 10, the National Credit Union Administration (NCUA) issued a guidance letter on the potential consumer harm of certain overdraft and NSF fee practices, offering strategies to help credit unions manage and mitigate these risks. 

​NCUA Final Rule on Succession Planning: On December 26, the NCUA published its final rule on succession planning for credit unions requiring that that a FICU board of directors establish a written succession plan that addresses specified positions, contains certain information and requires board of directors to regularly review the succession plan. 

Model Bylaws Subcommittee Confirms Virtual Ability to Hold Annual Meetings: The Minnesota Credit Union Network Model Bylaws Subcommittee worked with the Minnesota Department of Commerce Director of Credit Unions, Aeton de Long-Hersh, to confirm that Annual Meetings of state-chartered credit unions may be held in-person, remote, or by hybrid means. 

NCUA Board Adopts Final Rule on Succession Planning and 2025 Budget: On December 17, the National Credit Union Administration (NCUA) board met and unanimously adopted the final rule on succession planning with an effective date of January 1, 2026, requiring boards of directors of federally insured credit unions (FICUs) to establish written succession plans that cover specified positions, including board members, management officials and assistant management officials, and other positions that a FICU’s board deems critical.

​CFPB Finalizes Rule to Protect Homeowners: The Consumer Financial Protection Bureau (CFPB) finalized a rule mandated by Congress that applies existing residential mortgage protections to Property Assessed Clean Energy (PACE) loans. 

FTC Issues Advice On Preventing and Mitigating Digital Security Risks: On December 13, the Federal Trade Commission issued on its technology blog an advisory article to prevent and mitigate security risks through data management, software development and product design.