Financial Crimes Enforcement Network (FinCEN) 

FinCEN Adds New BOI Reporting FAQs 

FinCEN added additional FAQs to the BOI Reporting Frequently Asked Questions. The new FAQs include: 

• How will companies become aware of BOI reporting requirements? 

• Is a sole proprietorship a reporting company? 

• Have I met FinCEN’s reporting obligation if I filed a form or report that provides beneficial ownership information to a state office, a financial institution, or the IRS? 

• How does a company created or registered after January 1, 2024 determine its date of creation or registration? 

• Who can file a BOI report on behalf of a reporting company, and what information will be collected on filers? 

• Does the activity or revenue of a company determine whether it is a reporting company? 

• Does a reporting company have to report information about its parent or subsidiary companies? 

• Can a reporting company report a P.O. box as its current address? 

• Is an updated BOI report required when the type of ownership interest a beneficial owner has in a reporting company changes? 

• If a reporting company needs to update one piece of information on a BOI report, such as its legal name, does the reporting company have to fill out an entire new BOI report? 

• Can a filer submit a late updated BOI report? 

• If a reporting company last filed a “newly exempt entity” BOI report but subsequently loses its exempt status, what should it do? 

• What penalties do individuals face for violating BOI reporting requirements? 

• Who can be held liable for violating BOI reporting requirements? 

• Is a reporting company responsible for ensuring the accuracy of the information that it reports to FinCEN, even if the reporting company obtains that information from another party? 

• What should a reporting company do if a beneficial owner or company applicant withholds information? 

• Who can request a FinCEN identifier on behalf of an individual? 

• What type of evidence will a reporting company receive as confirmation that its BOI report has been successfully filed by a third-party service provider? 

• Will a third-party service provider be able to submit multiple BOI reports to FinCEN at the same time? 

___________________________________________________________________________________ 

Time to Review Branch Signage 

As we approach the end of 2023 and look forward to 2024, it might be a good time to review your branch signage. Several states will be updating their minimum wage posters for 2024. Your GoWest Compliance team has compiled branch signage requirements and include state specific requirements. 

BRANCH SIGNAGE REQUIREMENTS 

Posting Requirements 

Equal Housing Lender Poster: 

• Does the credit union visibly display the most current fair housing poster to all customers entering the credit union to make loan applications? 

• Does the credit union display the Equal Housing Lender/Opportunity Logo on their website? 

Reference Source

Fair Housing Act 

24 CFR 110.15 

12 CFR 701.31 (d) (2)  

Posting Requirements 

NCUSIF: 

• Does the credit union display the required share insurance signage at all stations or windows where deposits are received?   

• This does not include ATMs. 

• This does include drive up Teller Windows. 

• Does the credit union display the NCUA logo on their website? The logo should be large enough for a consumer to read without any action being taken (such as hovering over the logo). 

Reference Source

Share Insurance 

12 CFR 740.4 

Posting Requirements 

Funds Availability Disclosure 

• Is the Funds Availability Disclosure posted where it can be seen by a member prior to them making a deposit? 

• This excludes drive-up windows and night drops. 

• Is the Funds Availability Disclosure displayed at each proprietary ATM? 

• Do the preprinted deposit slips contain a notice that deposits may not be available for immediate withdrawal? 

Reference Source

Reg CC 

12 CFR 229.18 

Posting Requirements 

Home Mortgage Disclosure 

• Is the general notice about the availability of the HMDA data displayed in the lobby of the credit union’s home office and each branch office located in the MSA? 

Reference Source

Reg C 

12 CFR 1003.5 

Posting Requirements 

USA Patriot Act 

• Is notice that describes the credit unions identification requirements under the Patriot Act provided to members?  It may be provided as a notice in the lobby, on the website (for web-based account opening), as a notice with the account application. 

Reference Source

BSA requirements 

31 CFR 1020.220 (a)(5)(iii) 

Article VII, Section 6 (c) 

Posting Requirements 

Statement of Financial Condition 

• Is the statement of financial condition posted monthly in the lobby or each branch? 

Reference Source

Federal Credit Union Bylaws 

Posting Requirements 

Shared Branching Insured Credit Union Sign

• If the credit union participates in shared branching, does the credit union display the sign next to the NCUA Insurance Notice? 

Reference Source

Share Insurance 

12 CFR 740.4 (c) 

Posting Requirements 

ATM withdrawal fee disclosure on ATM 

• Does the credit union provide notice of a fee either on the machine or on the screen, prior to the consumer is committed to paying the fee?  

Reference Source

Regulation E 

12 CFR 1005.16 

OTHER CONSIDERATIONS 

Requirement 

Mutual funds, annuities, and other non-deposit investment products 

• If credit union offers investment products, ensure any signage or promotional material does not convey or suggest that the products are covered by share insurance. 

• The signage should inform the member that: 

• The products are not federally insured. 

• Are not obligations of the credit union? 

• Are not guaranteed by the credit union or any affiliated entity. 

• Involve investment risk, including the possible loss of principal, 

And, if applicable, are being offered by an employee who serves both functions of accepting members’ deposits and the selling of non-deposit investment products.

Reference Source 

NCUA Letter to Federal Credit Unions 

10-FCU-03 

Requirement 

Loan Interest Rates 

• If interest rates on loans are displayed for members, is the Annual Percentage Rate disclosed with equal prominence? 

Reference Source

Truth in Lending 

12 CFR 1026.16 

12 CFR 1026.24 

Requirement 

Share Account Dividend Rates 

• If dividend rates are displayed in lobby, is the Annual Percentage Yield provided? 

Reference Source

Truth in Savings 

12 CFR 1030.8 

12 CFR 707.8

EMPLOYEE SIGNAGE REQUIREMENTS 

FEDERAL

Posting Requirement - Federal

Employee Polygraph Protection Act 

Reference Source

US Department of Labor – WH Publication 1462 – July 2016

Posting Requirement - Federal

Equal Employment Opportunity 

Reference Source

EEOC-P/E-1 (Revised 6/2023) 

Posting Requirement - Federal

Your Rights Under USERRA – The Uniformed Services Employment and Reemployment Rights Act.

Reference Source

US Department of Labor – Poster Publication Date May 2021

Posting Requirement - Federal

Federal minimum Wage Poster 

Reference Source

Minimum Wage Poster (04/23) 

Posting Requirement - Federal

OSHA Job Safety and Health 

Reference Source

OSHA 3165-02  (2023) 

Posting Requirement - Federal

Family Medical Leave - Federal 

Reference Source

FMLA Poster  (04/2023)

Posting Requirement - Federal

IRS Notice 797 Possible Federal Tax Refund for Earned Income Credit

Reference Source

Notice 797 (12/2022) 

ARIZONA

Posting Requirement - Arizona

Arizona Minimum Wage 

Reference Source

AZ State Minimum Wage Poster 2024 (English) 

AZ State Minimum Wage Poster 2024 (Spanish) 

Posting Requirement - Arizona
Arizona Discrimination is Prohibited in Employment 

Reference Source

Arizona Law Prohibits Discrimination in Employment (8/2019)

Posting Requirement - Arizona

Arizona Notification of Constructive Discharge 

Reference Source

Notification of A.R.S. 23-1502 (8/2019) 

Posting Requirement - Arizona
Arizona Notice to Employees: You are Covered by Unemployment Insurance

Reference Source

POU-003 (8/2019) 

Posting Requirement - Arizona

Arizona Safety and Health Protection on the Job 

Reference Source

Employee Safety and Health Protection (10/2011)

Posting Requirement - Arizona
Smoke-free Arizona “No Smoking” Sign 

Reference Source

Smoke-Free Arizona (9/2019) 

Posting Requirement - Arizona
Arizona Work Exposure to Bodily Fluids

Reference Source

Work Exposure to Bodily Fluids (9/2019)

Posting Requirement - Arizona
Arizona Work Exposure to MRSA, Spinal Meningitis, or Tuberculosis 

Reference Source

Work Exposure Poster (7/2011) 

Posting Requirement - Arizona
Arizona Earned Sick Time Poster  

Reference Source

Earned Sick Time (English) (7/2017) 

Earned Sick Time (Spanish) (7/2017) 

COLORADO

Posting Requirement - Colorado

Colorado Overtime & Minimum Pay Standards 

Reference Source

COMPS Order #39 (1/2024)

Posting Requirement - Colorado 

Colorado Families & Workplaces Act and Public Health Emergency Whistleblower Law 

Reference Source

Colorado Workplace Public Health rights Poster (7/2023) 

Posting Requirement - Colorado 

Colorado Anti-Discrimination 

Reference Source

Colorado Anti-Discrimination Employment Poster (rev 10/2023) 

Posting Requirement - Colorado
Colorado Employment Security Act 

Reference Source

Notice to Workers (English) (4/2019) 

Notice to Workers (Spanish) (4/2019) 

Posting Requirement - Colorado
Colorado Notice to Employer of Injury

Reference Source

If You Are Injured on the Job (9/2019) 

Posting Requirement - Colorado

Colorado Notice of Paydays 

Reference Source

Payday Poster (8/2016) 

Posting Requirement - Colorado

Colorado Pregnant Workers’ Fairness Act 

Reference Source

Included in Colorado Anti-Discrimination in Employment Poster 

IDAHO

Posting Requirement - Idaho
Idaho Required Poster Package 

Reference Source

English Required Posters 

OREGON

Posting Requirement - Oregon

Oregon State Minimum Wage Poster

Both English and Spanish (Recommended, not Required) – Can be part of 9-in-1 Poster 

Reference Source

Oregon Minimum Wage Poster (2023) 

9 in 1 poster 

7 in 1 poster (24 or less employees) 

Posting Requirement - Oregon

Oregon Family Leave Act Poster – Can be part of 8-in-1 Poster

Reference Source

Oregon Family Leave (2023) 

Posting Requirement - Oregon

Oregon OSHA Poster – Can be part of 9-in-1 Poster 

Reference Source

Oregon OSHA Poster (2023) 

Posting Requirement - Oregon

Workers’ Compensation Notice of Compliance 

Reference Source

Oregon BOLI Posting Requirements (2023) 

Posting Requirement - Oregon

Oregon Breaks/Overtime Poster 

Reference Source

Oregon BOLI Posting Requirements (2023)

Posting Requirement - Oregon

Oregon’s No Smoking/Vaping  Poster 

Reference Source

Oregon No Smoking/Vaping (2023) 

Posting Requirement - Oregon

Oregon’s Senate Bill 519 

Reference Source

Notice of Rights Under Oregon Senate Bill 519 (2010) 

Posting Requirement - Oregon

Oregon Sick Time 

Reference Source

BOLI Requirements of Oregon’s Sick Time Law (2023)

Posting Requirement - Oregon

Oregon Equal Pay 

Reference Source

Oregon Equal Pay (2023) 

Posting Requirement - Oregon

Oregon Protections for Victims of Domestic Violence, Harassment, Sexual Assault & Stalking 

Reference Source

BOLI Requirements (2023) 

Posting Requirement - Oregon

Oregon Paid Leave 

Reference Source

Oregon Paid Leave (2023) 

WASHINGTON

Posting Requirement - Washington
Washington Department of Labor and Industry “Your Rights as a Worker in Washington State” 

Reference Source

F700-074-909 (10/2023)

Posting Requirement - Washington

Washington State Minimum Wage Poster

Both English and Spanish (Recommended, not Required) 

Reference Source

Minimum Wage posters (2024) 

Posting Requirement - Washington

Washington State “Unemployment Benefits” 

Reference Source

RCW 50.20.140 

EMS 9874.CC 7540-032-407 Rev 10/17 

Posting Requirement - Washington

Washington State “Washington State Law Prohibits Discrimination in Employment.” 

Reference Source

Washington State Human Rights Commission - Brochure (4/2015) 

Posting Requirement - Washington

Washington Department of L&I “Job Safety and Health Law” Poster 

Reference Source

Publication F416-081-909 (7/2022) 

Posting Requirement - Washington

Washington Department of L&I “ Notice to Employees – If a Job Injury Occurs”  On the job injuries. 

Reference Source

F242-191-909 (12-2012) 

Posting Requirement - Washington

WA State- No Smoking Signs 

Reference Source

Required at entrance  of all buildings  

RCW 70.160.050 

Posting Requirement - Washington

Washington State Paid Family and Medical Leave 

Reference Source

2024 English Poster 

Posting Requirement - Washington

Washington State Domestic Violence Poster

Reference Source

Domestic Violence Poster Rev 07/19

WYOMING

Posting Requirement - Wyoming

Wyoming-Specific Labor Law Posters

Reference Source
Labor-Law-Wyoming (9/2023) 

League InfoSight Highlight: We’ve Launched!!! 

By now, we hope you have seen the exciting news that we have launched the combination of CU PolicyPro and RecoveryPro onto a single site! Check out our press release for more information on this initiative and our future plans! 

Need a refresher or want to learn more about how you can use both products? Please check out our website where we provide additional resources on the new integrated platform! 

If any of you in the credit union industry have gone through a core conversion or any type of technology update, you know that there are thousands of tasks to do in order to be ready to “go live”! It takes the whole team to make everything a success! We’d like to give a special “thanks” and “cheers” to our amazing team and to our project lead, Mary Ann Koelzer (Senior Technology Products Manager), who went above and beyond and devoted nights, weekends, blood, sweat, and tears to make this launch successful!! 

Please just drop us a line and let us know what you think! As mentioned in the press release, this is the first step in a bigger project to consolidate all our products, including InfoSight, into one platform! What would you like to see in our final release? Your feedback always helps us craft and deliver superior products, so please keep the ideas coming! 

Thank you for trusting us to assist you with compliance! We don’t take that lightly and will continue to lead the way in compliance technology and the development of resources that keep pace with your needs! 

Glory LeDu,
CEO, League InfoSight and CU Risk Intelligence 

More form League InfoSight 

CEO Glory LeDu on Credit Unions, Coffee and Conversation Podcast 

Our very own CEO Glory LeDu was featured on the December 8, 2023 edition of Credit Unions, Coffee and Conversation podcast with Michigan Credit Union League's CEO Patty Corkery! Listen to the interview as Glory talks about what's on the regulators' agendas and how League InfoSight stays on top of current compliance issues, such as fraud, to best help credit unions navigate these trends. 

Cybersecurity Resources 

A recent ransomware incident has affected more than 60 credit unions nationwide. A list of resources has been added to InfoSight under the Security channel and included directly on the dashboard to provide general insights on cybersecurity incidents and guidance on preventive measures for the future. 

Joint Statement on EU-U.S. Financial Regulatory Forum 

IRS Issues Standard Mileage Rates for 2024; Mileage Rate Increases to 67 Cents a Mile

FTC Announces CARS Rule to Fight Scams in Vehicle Shopping 

Fake Shipping Notification Emails and Text Messages: What You Need to Know This Holiday Season 

Dec. 25: Christmas Day (Federal Holiday)

Dec 29: Comments Due CFPB Proposed Rule on Personal Financial Data Rights 

Jan. 8, 2024: Comments Due NCUA Proposed Rule on Fair Hiring in Banking  

Jan 22, 2024: Comments Due FinCEN Proposed Rule on CVC Mixer Reporting 

Feb. 12, 2024: Comments Due FRB Interchange Proposal 

Dec. 26, 2024: Comments Due NCUA Proposed Rule

Do the higher priced mortgage requirements apply to rental property? 

The higher priced mortgage requirements under Reg Z 1026.35 apply to consumer credit transactions secured by the consumer's principal dwelling.  Rental property is not covered under this and therefore does not need to meet the higher priced mortgage requirements. 

For your individualized login, select your state below. 

If you have questions about this communication, contact us at 800.546.4465, or via our shared email inbox at compliance@gowest.org.

Have a great week!

Your GoWest Compliance Team, 

Copyright © 2023 GoWest Credit Union Association. All Rights Reserved.

Mailing Address:
GoWest Credit Union Association, 18000 International Blvd Ste. 1102, SeaTac, WA 98188, United States
1.800.995.9064

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