NAFCU Compliance Blog

Common Compliance Violations: Account Opening Disclosures for Open-End Credit

Written by Steve Van Beek

We've discussed the Philadelphia Federal Reserve's Consumer Compliance Outlook a few times - including the following common compliance violations:

• Regulation B - Spousal Signatures
• Regulation B - Adverse Action Notices

Today, I wanted to highlight a common Reg Z violation (according to Federal Reserve examiners) which stems from the multitude of changes in Regulation Z over the past 3-4 years.  And, unfortunately, we ain't seen nothing yet!

Regulation Z - Account Opening Disclosures for Open-End (Not Home-Secured) Credit Plans.  Here is the description of the issue from the Philadelphia Federal Reserve:

"The Board of Governors of the Federal Reserve System (Board) amended some of the Regulation Z disclosure requirements for open-end credit (not home-secured) in a January 2009 final rule that became effective July 1, 2010.¹⁷The changes include new requirements for account-opening disclosures.¹⁸ Consumer testing revealed that consumers responded favorably to a table format that summarized key terms (based on the Schumer Box format used for credit card solicitation and application disclosures). As a result, the Board required in 12 C.F.R. §1026.6(b)  that creditors use a table format substantially similar to model form G-17 to disclose certain key account terms.¹⁹

The failure to use a table format substantially similar to model form G-17 has been a frequent violation for account-opening disclosures for overdrafts and personal lines of credit. As with the RESPA tolerance requirements, this violation reflects the compliance challenges that arise with a significant regulatory change. Financial institutions relying on third-party software to create disclosures should verify that the software reflects the changes in regulatory requirements. For internally created software, institutions should ensure that regulatory changes are communicated in a timely manner to the IT department and that the software is tested to verify that the changes have been implemented. For a more detailed discussion of vendor risk management, refer to the Outlook article “Vendor Risk Management” in the First Quarter 2011 issue.^20"  (emphasis added).

As the underlined text indicates - this is an issue partly because of the magnitude of regulatory changes and the inability for smaller institutions to simply keep up.  

Inadequate Model Forms.  I'd also like to add another observation on why this might be a common compliance issue.  The model forms for these disclosures are located in Appendix G to Regulation Z.  From Appendix G, the account opening tables are the G-17 Series:

• G-17(A) Account Opening Model Form
• G-17(B) Account Opening Model Form
• G-17(C) Account Opening Model Form
• G-17(D) Account Opening Model Form

The article indicates that "the failure to use a table format substantially similar to model form G-17 has been a frequent violation for account-opening disclosures for overdrafts and personal lines of credit."

If you click through the model form links above, you'd see that G-17(A); G-17(B) and G-17(C) are all designed as model forms for credit card accounts.  Only G-17(D) provides any guidance on open-end account opening disclosures for non-credit cards.  Thus, three of the four forms are designed for credit cards and not other types of open-end products. 

I wonder if that is part of the reason this is a common compliance violation?  And - this is the part of the feedback loop that the CFPB needs to improve on if it truly wants to lessen the regulatory burden on smaller institutions.  If there are numerous compliance violations - the CFPB needs to look internally and see if their regulations, forms and guidance are making the requirements clear and straightforward.  

Work with Us.  Other regulators have not succeeded in the past and they also haven't shown much effort.  Usually, the regulation gets promulgated and that is the end of it.  But that isn't good enough.  It isn't good enough for the regulator, it isn't good enough for credit unions and it isn't good enough for consumers.  The real test is whether the CFPB improves in the future or whether it follows the same old story.  

The Origin of a Q&A; Hi my name is…

Written by Michael Coleman, Regulatory Compliance Counsel

Greetings fellow compliance professionals! For those of you who do not know me, I am Mike Coleman, the newest Regulatory Compliance Counsel here at NAFCU. As this is my inaugural blog post, I promised Steve I would not “break the blog.”

***

If your credit union is a NAFCU member you are probably familiar with NAFCU’s Compliance Monitor, our monthly compliance newsletter. One of the features of the Compliance Monitor is the Compliance Forum, which includes questions and answers written by our Compliance Team. You may have asked yourself, “Where do they come up with these questions?” The answer is from our NAFCU members!

Answering compliance questions is one of the major member services NAFCU’s Regulatory Compliance Division provides our members. We get a lot of questions. Sometimes we see a pattern of questions on a particular topic, particularly after there has been a recent regulatory amendment. Sometimes we get a unique question that we just feel compelled to share. When this happens, we start drafting Q&As.

Here is an example of a Q&A that might be featured in the Compliance Monitor:

Question: At our credit union we understand that the Credit CARD Act, and the resulting changes to Regulation Z, prohibits increasing an APR within the first year of account opening. However, we want to increase the annual fee for a credit card account which is six months old. Is this permissible?

Answer: No.  Regulation Z contains special protections for credit card accounts which stem from the requirements of the Credit CARD Act of 2009. Regulation Z contains a general prohibition for the increase of an APR or a fee required to be disclosed at account opening unless an exception applies. Section 1026.55(b)(3) of Reg Z provides an “advanced notice exception”, which allows a credit union to use the 45 day change-in-terms process to increase an APR or a fee. However,  Section 1026.55(b)(3)(iii) specifically prohibits a credit union from increasing a member’s APR or certain fees required to be disclosed in the account opening table during the first year of the account:

“(iii) This exception does not permit a card issuer to increase an annual percentage rate or a fee or charge required to be disclosed under §1026.6(b)(2)(ii), (iii), or (xii) during the first year after the account is opened, while the account is closed, or while the card issuer does not permit the consumer to use the account for new transactions. For purposes of this paragraph, an account is considered open no earlier than the date on which the account may first be used by the consumer to engage in transactions.”

(Emphasis added.) 12 C.F.R. §1026.55(b)(3)(iii).

The annual fee for a credit card account is one of the fees required to be disclosed under Section 1026.6(b)(2)(ii), therefore, increasing the annual fee during the first year after the account is opened is prohibited.

This Q&A is an example of a particular question that came in and we thought it would benefit all our members to get an answer, so we drafted a Q&A for the Compliance Monitor.

***

Just to add my own personal disclaimer, I grew up in the DC Metro area (in Falls Church, Virginia) and as such am an avid Redskins, Capitals, and UVA fan. In addition to Steve’s usual plugs about everything Michigan, I will do my best to keep you updated on the trials and tribulations of being a sports fan in DC. Here’s hoping RG3 lives up to the hype! 

CFPB Industry Discussions; Reg Z Proposal for Credit Cards

Written by Steve Van Beek

If you are located in either the Cleveland or New York City areas, you might be able to get a chance to listen to the CFPB in-person.  The CFPB has two "Industry Discussions" listed for later this spring.

• Friday, April 27th in Cleveland, Ohio
• Friday, May 4th in New York City, New York

You can also hear from CFPB Director Cordray during NAFCU's Free Webcast on April 24th.  The Webcast is open to all credit unions but registration is required.    

***

Last Thursday, the CFPB issued a proposed rule to amend Section 1026.52(a) of Regulation Z.  I know what a lot of you are thinking - another change to the Credit CARD Act regulations?  Another clarification?

Well, yes.  But, this one shouldn't impact many credit unions as it relates to the cap on fees credit unions can charge during the first year of a credit card.  Here is the current 12 CFR 1026.52(a):

"§ 1026.52   Limitations on fees.

(a) Limitations prior to account opening and during first year after account opening.(1) General rule. Except as provided in paragraph (a)(2) of this section, the total amount of fees a consumer is required to pay with respect to a credit card account under an open-end (not home-secured) consumer credit plan prior to account opening and during the first year after account opening must not exceed 25 percent of the credit limit in effect when the account is opened. For purposes of this paragraph, an account is considered open no earlier than the date on which the account may first be used by the consumer to engage in transactions.(emphasis added).

***

What is the CFPB proposing?  The CFPB is proposing to remove the "prior to account opening" language from Section 1026.52(a) and, thus, the restriction on fees would only cover fees charged after the account is opened.  

Why is the CFPB doing this?  Isn't this weakening the rule?  The Federal Reserve originally wrote this rule and was sued by an institution arguing the Fed went beyond the requirements of the Credit CARD Act.  There are good stories on the CFPB's move here (New York Times) and here (Washington Post).   

***

The Short Version.  This proposal won't directly impact most credit unions as they are not offering credit cards with large amounts of fees in the first year or prior to account opening.  However, other card issuers might be able to move back to their prior business model of charging processing fees prior to account opening.    

To see the specifics of the proposed change, click here to see the Federal Register (the bracketed text indicates that text - "prior to account opening" would be removed if the rule was finalized).   

Note:  If you are looking for which fees count toward the 25% cap during the first year - scroll down in the staff commentary to 12 CFR 1026.52(a)(2).  

A Few CFPB Items

Written by Steve Van Beek

Below are a couple of CFPB-related items for your Tuesday morning:

• Last Thursday, the Senate failed to confirm Richard Cordray as Director of the CFPB.  It is starting to look more and more like the CFPB will be without a Director until after the 2012 Elections.

• The CFPB recently announced its Ombudsman's Office.  From the CFPB's blog:

"At the CFPB, the Ombudsman’s Office will assist in the resolution of individual and systemic issues that a depository entity, non-depository entity, or consumer has with the CFPB. People may use the Ombudsman’s Office when they have not had success with the existing CFPB processes, or to achieve an informal resolution. Others may contact the Ombudsman to keep their concerns confidential.

Starting today, the CFPB is officially opening the doors of the Ombudsman’s Office under the direction of our Acting Ombudsman, Wendy Kamenshine. Wendy now is ready to hear from the depository and non-depository entities we regulate on issues concerning our supervisory and enforcement processes. She looks forward to hearing from consumers beginning in the spring."

• The CFPB also recently issued a report on credit card complaints.  The CFPB blog post is here with the full report here.  

In addition to the report on credit card complaints, the CFPB proposed a policy statement related to disclosure of credit card complaint data.  Part of the disclosure would include a publicly available database including information on complaints to card issuers with over $10 billion in assets.  

NAFCU has issued a Regulatory Alert on this policy statement (11-EA-33).  

Know Before You Owe: Credit Cards

Wrtiten by Steve Van Beek

Well, the CFPB wasn't lying when it stated its initial focus would be on mortgages, credit cards and student loans.  We now have "Know Before You Owe" projects for each one.  

• Know Before You Owe: Mortgage Loans

• Know Before You Owe: Student Loans

• Know Before You Owe: Credit Cards

***

Yesterday, the CFPB announced their first steps toward clarifying and condensing credit card agreements.

• Press Release

• Prototype Credit Card Agreement

• Listing of Definitions for Prototype Agreement

The announcement also came with a pair of blog posts from the CFPB.  

• Shopping for a Credit Card

• Making Credit Card Agreements Understandable

Similar to the other Know Before You Owe projects, the CFPB is actively soliciting feedback on their prototype.  Importantly, this is not a proposed rule.  However, it is the CFPB's first steps toward collecting information and attempting to clarify credit cards for consumers.  (I'm sure many compliance officers are wanting some clarification as well - and not the kind of "clarifications" the Fed dropped on everyone earlier in 2011).

***

If your credit union offers credit cards, be sure to review the prototype.  It might be a good idea to have preliminary discussions with your forms provider as well.  Would they be able to make these changes?  How long would that take?  At what cost?   

This also might be a good time to put together a summary of the headaches during the last round of "tweaks" to credit card disclosures.  Detailed, specific information on the timeframe, steps and costs to comply with the most recent changes to credit cards would be very useful during the prototype stage and especially during any future proposed rulemakings.  

Regulation Z's Clarification: Track that Variable Rate

Posted by Anthony Demangone

In the past week or so, we've tried to highlight a few areas where regulations can be quite difficult to follow. Here's another example, coming out of the Fed's recent 300+ page CARD Act "clarification" rulemaking. The rule becomes effective October 1, 2011. If your credit union converted your credit card program from a variable to a fixed rate recently, please put down your coffee and move anything that you can throw that is currently within your arm's reach into a desk drawer.  And then lock that drawer. 

Ready?

Issuers are generally required to reevaluate rate increases at least every six months.  Regulation Z clarifies that a change from a variable rate to a fixed rate, or vice-versa is not a rate increase that triggers the obligation to reevaluate, if the rate in effect prior to the change is the same as, or higher than, the new rate.  However, the Board added new comment 59(a)(1)-3.iii in its "clarification." The new comment creates an obligation to reevaluate if a creditor switches an account from a variable rate to a fixed rate and the variable rate decreases at some later time, leaving the cardholder paying a higher rate than he would have absent the creditors’ decision to change from a variable to a fixed rate.  The comment below explains the situation.

“[A]ssume a new credit card account…is opened on January 1 of year 1 and that a variable annual percentage rate that is currently 15% and is determined by adding a margin of 10 percentage points to a publicly-available index not under the card issuer’s control applies to all transactions on the account.  On January 1 of year 2, upon 45 days’ advance notice pursuant to § 226.9(c)(2), the rate on all existing balances and new transactions is changed to a nonvariable rate that is currently 15%. The change from the 15% variable rate to the 15% non-variable rate on January 1 of year 2 is not a rate increase for purposes of § 226.59(a). On April 1 of year 2, the value of the variable rate that would have applied to the account decreases to 12.5%. Accordingly, on April 1 of year 2, the non-variable rate of 15% exceeds the 12.5% variable rate that would have applied but for the change in type of rate. At this time, the change to the non-variable rate of 15% constitutes a rate increase for purposes of § 226.59, and the card issuer must begin periodically conducting reviews of the account pursuant to § 226.59. 

Consequently, issuers that convert accounts from variable to nonvariable rates must track the old variable rate, which no longer applies to the account, as a decrease in that index may give rise to the obligation to reevaluate accounts that now have a fixed rate.  The example shows a hypothetical where the review is triggered on April 1, of "year 2." But this requirement to compare your fixed rate against the old, dead, variable rate could trigger a review in "year 40."  Add this to the mix: If your credit union has take part in a number of mergers and you've incorporated their card programs into your program, the complexity of the review process could be fierce. You'll need to know the history of their rate change decisions to get a good picture of your rate review responsibilities. 

Oversight of CFPB; This and That; Still a Tourist

Posted by Anthony Demangone

Earlier this week, I had the pleasure of attending a luncheon where Congressman Spencer Bachus (R-Ala.) addressed a gaggle of regulatory peeps.  Rep. Bachus is a big deal in Washington, as he is the Chair of the House Committee on Financial Services.   He spoke about a number of issues, including his views of the CFPB. 

He viewed the new agency as potentially problematic, laying out three basic reasons for his view.

• While Elizabeth Warren is not technically the Director, she is hiring everyone who will "count" at the CFPB.   Those new hires will be molded by Ms. Warren. Mr. Bachus doesn't see eye-to-eye with Ms. Warren on the role of regulation, so he sees an agency of Warren-ites as troubling.  Mr. Bachus' views are very interesting in light of this article from the L.A. Times. 

In any case, Warren is already aware that fresh blood is needed in the regulatory arena. She said she wants to avoid hiring nothing but older, seen-it-all-before bureaucrats who may be set in their ways.

"We're going to hire new, young staff and train them to follow the law," Warren said.

Hey, wait a minute. Isn't that the script for "The Untouchables"?

"That's what I'll be renting this weekend," she said, laughing.

• He noted that the CFPB will increase regulatory burdens.  But he added something that is missed by many.  When a new set of regulatory hurdles is put in place, those hurdles have a greater impact on smaller businesses.  So, credit unions and community banks, entities that don't have a ton of resources to throw at compliance and legal risks, will be affected the most.  This remains to be seen, but it is a concern that I share with Mr. Bachus.  I understand that Ms. Warren wants to level the playing field so that good actors are not competing against bad actors with one arm tied behind their backs.  But if the smaller good actors are using both hands to deal with new regulatory requirements, we won't have any free hands to compete with anyone.
• Mr. Bachus also noted that financial regulators must balance consumer protection with safety and soundness.  If the only products that a financial firm is allowed to offer do not make money, that firm is in a world of trouble. 

Mr. Bachus' comments are a reminder of the complex dance that is done in Washington, D.C.  Ms. Warren has her marching orders. She is building the CFPB.  But checks and balances are in place, and Mr. Bachus has indicated that he'll use his position and power to keep an eye on things at the CFPB.  

***

Here are a few items of interest.

• The CFPB will host a "credit card conference" next Tuesday to measure the impact of the Credit CARD Act.

We will bring together academics, industry leaders, consumer advocates, and voices from within government to look at the data from multiple directions, and to analyze how the industry has reacted and how consumers are responding. The idea is to establish a fact base upon which the CFPB can improve our understanding of the impact of the CARD Act and to help us understand how we can make credit markets work better.

• The FFIEC announced its new and improved IT Examination Infobase.   The announcement doesn't signal a change to the FFIEC's IT handbook, but the FFIEC believes the change should improve access to guidance and the ability of the FFIEC to update guidance in the future. The IT Examination Handbook is a huge source of valuable guidance.
• NAFCU has entered into an agreement with Sheshunoff and Thompson that benefits the entire credit union industry. NAFCU was able to negotiate a credit union discount for the entire Sheshunoff and Thompson libraries of content. If you find a manual or product that tickles your fancy, use promo code NAFCU11 at checkout when you purchase or renew the product to save 10%.  Learn more about this new development here.

***

I arrived a bit early for the luncheon with Rep. Bachus, so I had about 5 minutes to kill.  Those five minutes became a personal pep-talk. I've lived in the D.C. area since 1996.  The traffic may be bad and the work may be hectic, but part of me will always be a tourist that is overwhelmed by Washington, D.C. and the institutions and places it hosts. 

 

NCUA Board Meeting Agenda Available; More on Elizabeth Warren

Posted by Anthony Demangone

NCUA has released the agenda for this Thursday's board meeting. This meeting practically overflows with big compliance issues.  Such as...

• NCUA will issue a final rule concerning Fiduciary Duties.  (The rule also addresses merger and conversion issues.)  This rule is a big deal, as it will create federal standards of duty and care. In addition, NCUA may clarify expectations on financial literacy and educational requirements concerning federal credit union boards. 
• A proposed rule regarding insurance coverage for non-interest bearing transaction accounts. 
• A proposal to amend NCUA's "accuracy of advertising and insured status" regulation.  
• There's other stuff as well, so please review the agenda.

More on Elizabeth Warren.  Here are a few additional items regarding Elizabeth Warren. (I keep focusing on news stories where she is quoted, as I find her views important.  She's putting the CFPB together, so her views be stamped into the new agency.)

• Earlier, I noted this article from Kiplinger.But I forgot to highlight a very telling quote from Ms. Warren. Here's the last Q and A from the article:

"What's your advice for Kiplinger's readers while they're waiting for this to happen? Anyone who carries credit-card debt from month to month is in financial trouble. This is not a normal state, nor is it sustainable over time. Not paying off that credit card is always a bad sign, so pay it off. That's my best advice."

Whoah, Nelly! Anyone who carries credit card debt month-to-month is in trouble? Really? I understand that it is sound financial advice for consumers to pay off their credit card debts each month when possible.  But to assume that anyone carrying any balance is in trouble goes a bit far. There is a product that requires consumers to pay off their balance each month.  It is called a charge card.  A credit card is designed to be used, and carrying a balance is a basic option of the product.  This quote makes it seem that Ms. Warren finds credit cards, by their very nature, to be fundamentally bad for consumers. Sort of financial cigarettes, if you will. 

• Elizabeth Warren also participated in a "question and answer" session highlighted by the U.S. Treasury.  There's no way her quotes were taken out of context here, as Treasury itself controlled the content.  I've inserted my snarky commentary as necessary in bold text. 

1) With hundreds of problems in the consumer financial products and services marketplace that the CFPB could chose to focus on, how do you decide where to dive in and begin? What have your top priorities been out of the blocks?

Credit cards are a top priority because they are the most widely held credit product in the country. Four out of five families have a credit card and 50 million American families cannot pay off their credit card debt each month in full.  Man, she hates credit cards. Forget payday lenders, fly-by-night "credit repair companies, and auto-title loan companies.  Credit cards are front and center on her agenda.  

 

Mortgages are the other top priority because they are the single most important financial decision that most families will make. We have learned from recent history that a bad mortgage can not only destabilize an entire family, but that enough of them can destabilize the entire economy.

 

2) You frequently cite streamlining disclosures as a way to level the playing field and give families better tools to make the choices that are best for them.  When will consumers start seeing a difference?

Consumers can already see a difference. Look at what the banks are advertising right now and see how often phrases like “simplicity,” “no tricks” and “clarity” are showing up. The industry recognizes that these consumer credit markets have to change.  Advertising is not always the best measure of progress.  Case in point.   Personally, I think a consumer advocate would do better to look at ads like these. (YouTube.com) Do American consumers rack up debt because of credit cards, or because we've created a national culture of consumption?

 

3) Your first week on the job, you and Secretary Geithner held a mortgage disclosure forum at Treasury and just this week, the CFPB implementation team held a follow up symposium. What have you learned from these sessions?

The current disclosures increase costs for lenders while providing very little benefit for consumers. We've been saying this for years. We want to reverse that and decrease the costs of disclosure while increasing the value to consumers. The way to do that is to make that disclosure clearer and more usable for consumers.  Amen. 

 

4) You’ve spoken a lot about how the consumer credit market is “broken.” How do we know the market isn’t working and what can the CFPB do to fix it?

When a family cannot tell the cost in full of a credit card, when it is not possible to determine the risks of a mortgage in advance, and when people can’t directly compare three or four products– apples to apples – to tell which costs the most and which bears the most risk, then the market is broken.

 

This agency will drive toward making the costs clear, making the risks clear, and making it easy for consumers to compare one product with another. When they can do that, credit markets will work for families.  Keep in mind that many regulators have gone before you with this same task in hand.  The Federal Reserve has spent a good deal of time on consumer issues and consumer testing of financial disclosures.  No matter how much work you throw into this, keep in mind that you'll run into one basic problem: many consumers simply do not attempt to read disclosures.  I agree that some credit card agreements are complex, but the Schumer Box gives consumer more than enough information to compare credit card products.  And to say that the mortgage problems we face today are due to poor disclosures while not talking about broker misrepresentations, predatory lenders, and consumer responsibility is simply not telling the whole story.  

 

5) What roles will personal responsibility and financial education play in the consumer credit market once the CFPB is stood up?

I believe in personal responsibility, but it only works when prices and risks are clear up front and not buried in pages and pages of incomprehensible fine print. But, I also believe in American families. When they have better information they will make good decisions and those good decisions will make families stronger and ultimately will make the entire economy stronger.  I am not aware of any credit union in America that buries the cost of a mortgage or credit card.  They may exist, but I don't deal with them.  The Schumer Box, MDIA, RESPA and Truth in Lending generate a ton of price-related information for consumers.  But consumers have to take responsibility.  It is disappointing that when directly asked about consumer responsibility, Ms. Warren takes another shot at lenders for their alleged sins.

This and That...

Posted by Anthony Demangone

Here are some items of interest.

• You may have caught on to the fact that I enjoy reading the works of Felix Salmon.  In this post, Mr. Salmon dissects a disclosure he received from his bank.  As you'll read, the disclosure is nearly impossible to understand.  The post is a nice reminder of this fact: we write or disclose words to communicate. What are you trying to say?  Once you know that, say it as clearly as possible.  There are times when we must use precise words or "legal terms of art."  Outside of those times, though, writing or disclosures should be clear and easy to understand.  Don't use 50-cent words when a nickel buys you exactly what you need. Don't force readers to choose between confusion and reaching for a dictionary.  And you should hire a monkey to slap you whenever you use any of the following terms in a document meant for general consumption: heretofore, whereas, or any Latin phrase.  
• The Fed has updated its Consumer Compliance Handbook.  Here's how I use these handbooks.  Someone may ask you for an overview of Regulation E.  You know all about Regulation E, but you are swamped.  Why not refer them to the Reg E portion of the handbook? Or use the handbook when building a training program to make sure you don't forget something important.  In an age of increasing work demands, always lean on trusted resources whenever possible. 
• I'll say this, Elizabeth Warren certainly isn't shy when speaking about her plans for the CFPB. In her cross-hairs? Credit cards and mortgages.   (Kiplinger.com) (Hat tip to Mr. Harrigan.)

This and That...

Posted by Anthony Demangone

Here are a few items that I wanted to share.

• NAFCU's senior management team and board of directors just visited the Federal Reserve.  For our annual visit, we always prepare our "Fed Report," which you can download here.  For those who write articles, board reports, or other industry-related items, the report provides a nice overview of the credit union industry. 
• Here's an interesting piece (Governance and Strategic Planning Blog) on the Audit/Supervisory Committee's possible role concerning credit union policies. 
• The FTC has released these gift card buying tips. If your credit union has a blog, Twitter feed or Facebook page, this might be something nice to share.
• Now that most credit card issuers must submit their agreements to Fed, we can expect more articles and blog postings like this one from Felix Salmon.  The article links to two lists - the 10 most difficult to read credit card agreements, and the 10 wordiest credit card agreements.  Credit unions are on both lists. I'd check to see if your shop is on either list. 
• In the midst of the current recession, it seems that financial illiteracy/indifference may be increasing. (Walletpop.com)  I'm all for financial literacy, but sometimes I wonder how useful all the efforts are to force financial literacy down the throats of consumers.  It seems to me that when someone is interested in their finances, there's more than enough information available to answer their questions.
• It seems the GOP will hold the CFPB's feet to the fire. (WSJ.com)  As much as they can, anyway. 
• NCUA recently issued the latest batch of its Prohibition orders.  If anyone out there thinks insider fraud isn't a problem, they should take a look at these orders.  One involves an order for restitution for more than $2 million.