Compliance Update – July 2021

2021 IRS Form Changes

BMA has received the updates and changes to the IRS forms for 2021. The changes have been reviewed and approved in our Work in Progress meeting and sent to development to start the process of updating the BankRite Touch System.

Change Highlights:

1098 – Verbiage updates and changes 1098-T – Minor word change to clarify the instructions 1099-DIV – Changes to box 2c and box 2f 1099-MISC – Changes in title, box 7, caption, and box 11 1099-NEC – Form size update and changes in amounts to box 2 The updates appear to be significantly less than in prior years.

Reference: IRS Information Return Forms for Tax Year 2021

Credit Reporting Guide Updates

The Consumer Data Industry Association (CDIA) has published and updated version of the Credit Reporting Resource Guide (CRRG).

Change Highlights:

Credit Cards (Non-Retail)

• Account Status Field has added a note clarifying reporting status “13” Retail Accounts (Store Exclusive)

• Portfolio Type “R” has added a note to reporting statue “13”

Field Definitions

Base Segment Field 13 Terms Duration

Base Segment Field 18 Payment History Profile

Base Segment Field 22 Amount Past Due

K4 Segment update the Verbiage with an explanation

There are number of other changes and updates for Credit Reporting. Please us the reference for addition information.

Reference: Credit Reporting Resource Guide: April 2021

Question: Is training required under the Bank Protection Act (BPA) Regulation?

Answer: Yes. It is the responsibility of the Bank Security Officer to ensure that all bank personnel are trained on the security program. Initial and periodic training is required.

Reference: FED 12 CFR 208.61; OCC 12 CFR 21; FDIC 12 CFR 326

Question: Your bank’s marketing department want to attract savings deposits. They would like to hold a raffle, where the customers who open a savings account are entered to win a prize. Are there any restrictions under the law?

Answer:Federal Banking Law that prohibit banks from engaging in a lottery, was revised via the American Savings Promotion Act of 2014 to include that the term lottery does not include “savings promotional raffle”, as codified under law (see applicable law for your banking agency).

The term “savings promotion raffle” means a contest in which the sole consideration required for a chance of winning designated prizes is obtained by the deposit of a specified amount of money in a savings account or other savings program, where each ticket or entry has an equal chance of being drawn, such contest being subject to regulations that may from time to time be promulgated by the appropriate prudential regulator (as defined in section 1002 of the Consumer Financial Protection Act of 2010 (12 U.S.C. 5481)).

Consideration: Some interpretations state because the customer is paying “a thing of value” for consideration of a prize it is a lottery.

Reference: OCC 12 USC 25a; FED Section 9a of Federal Reserve Act; FDIC section 20 of Federal Deposit Insurance Act. See also: Consumer Financial Protection Act of 2010 Section 1002 “definitions” for prudential regulator; The American Savings Promotion Act of 2014 (PUBLIC LAW 113–251); and Regulation DD