NAFCU Compliance Blog

What Does Your Board Need to Know About the CFPB?

Written by Steve Van Beek

The headline above was my goal when I created a presentation for NAFCU's Board of Directors & Supervisory Committee Conference next month in Asheville, North Carolina. The first point is that the CFPB's regulations apply to all credit unions.

After that, you can see my overview and key takeaway slides below.

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It's Not Too Late. Your Board can still sign up for the conference - May 15-17 in Asheville, NC - and we'll be having similar discussions at NAFCU's Annual Conference - July 9-13 in Boston, Massachusetts.  

Here is another question: How are you informing and updating your Board on the CFPB's actions (and potential actions)? 

2013 HMDA Getting it Right Guide; New NAFCU Calendar; Reg Alert on Escrow Proposal

Written by Steve Van Beek

2013 HMDA Guide. Yesterday, the Federal Financial Institution Examination Council (FFIEC) issued the 2013 HMDA Getting it Right! guide. According to the main page:

"The 2013 edition reflects the transfer of authority over Regulation C from the Federal Reserve Board to the Consumer Financial Protection Bureau. Appendix D, comment 1003.2 (Financial Institution)-2 is updated with the asset-size threshold exemption applicable to collection of 2013 data. There are also minor changes to the general text of the Guide, including updates to Sources of Geographic Information and Submitting the LAR."

You can find the full PDF of the 2013 Guide here.  

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Long Time Coming. Now, you may be wondering when the last version of the Guide was issued?  2010.  The 2011 version would have been the lame duck one when the Federal Reserve still had authority for Regulation C (HMDA). However, there was no guide issued. On July 21, 2011, the CFPB took over Regulation C and they failed to release a guide in 2012.  Fortunately, in year two, the CFPB found the time to update the Guide and provide guidance to HMDA-reporting institutions.

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Garbage In, Garbage Out? The CFPB is a self-described "data-driven" agency. If you doubt it, take a read through this Bloomberg.com story: U.S. Amasses Data on 10 Million Consumers as Banks Object. To me, if you want to be data-driven - the best first step is to make sure your regulatory requirements are clear and understandable so that the data you collect (whether it be consumer complaints, HMDA data, or anything else) is as reliable as possible. But, that's just me.  

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NAFCU Calendar.  NAFCU has a new calendar on our website that features:

• Compliance Deadlines;

• Important Regulatory Dates;

• Education & Conferences;

• CU Research Survey Deadlines; and

• Other Important Dates.

The calendar allows you to navigate month-by-month, click to find more information and add dates to your own calendar. For example, the "more information" link on the June 1st Escrow Changes Deadline includes this information:

CFPB Compliance Deadline: Escrow Requirement

Description:

Amended escrow requirements for higher-priced mortgage loans. Added a new small creditor exemption for credit unions that meet a four-part test.

Regulatory Text: 12 CFR 1026.35

NAFCU Compliance Blog: Mortgage Reform - Escrows

NAFCU Resources: www.nafcu.org/mortgagerules/#escrow

Download the latest full Compliance Calendar, including proposed regulations, past deadlines and more.

Date:Jun 01, 2013    

Add to Calendar                                             Back to Calendar

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NAFCU Members. The Mortgage Rules webpage includes NAFCU's Regulatory Alert on the CFPB's recent proposed rule. The proposal was published in the Federal Register yesterday and only provided 15-days for comments (comments to NAFCU on the Regulatory Alert are due on Wednesday, April 24).  

CFPB Expands Consumer Complaint Database Information; #Reputation Risk?

Written by Michael Coleman, Regulatory Compliance Counsel

We have blogged several times on the CFPB’s Consumer Complaint Database (and we even created a member complaints category for the blog) and its implications for credit unions, most recently, here. Initially, it is important to keep in mind that credit unions under $10 billion are not included in the Consumer Complaint Database.  The CFPB will forward any complaints from these credit unions to NCUA, and credit unions will need to follow NCUA's procedures for responding to member complaints, which we’ve outlined a couple of times on the blog.  Most recently here and here.

Well, the CFPB is at it again. On March 28^th, 2013 the CFPB announced in a press release and on its blog that they have expanded the consumer complaint database. The database now includes more than 90,000 complaints on mortgages, student loans, bank accounts and services, other consumer loans, and credit cards.

We have expressed our concern numerous times over the fact that the consumer complaint database contains unverified complaint information, and the danger that this poses to a credit union’s reputation risk in this age of viral media. Once that information is out there, you can’t un-ring that bell.

The CFPB acknowledges the fact that this data is unverified in a disclosure on the compliant database, but it doesn’t really jump off the page. Nor does their rationale for listing unverified data in their policy statement really resonate (see page 9), or the “significant controls” for verification in this policy statement on the release of credit card compliant data.  

Instead of beating that drum again, I’d like to focus on what I considered a particularly troubling excerpt from the CFPB announcement:

“A Call to Action

The CFPB is encouraging the public, including consumers, analysts, developers, data scientists, civic hackers, and companies that serve consumers, to analyze, augment, and build on the public database to develop ways for consumers to access the complaint data or mash it up with other public data sets.

The CFPB would like the public to highlight innovative uses of the data, from visualizations to new tools, by tweeting @CFPB using the hashtag #CFPBdata.”

Admittedly, I am what you might call technologically challenged (just ask any of my colleagues, if the printer is broken, its most likely my fault), and I have no idea how Twitter actually works. Still, I don’t know about you, but this makes my eyes start twitching and I want to employ Steve’s stress reduction kit. There is a great recap of “the new cycle” of regulation in this blog post, highlighting the fact that the solicitation of complaints can ultimately result in the passage of laws or the issuance of regulations that will apply to all credit unions, not just those over $10 billion in assets.

But the CFPB has taken it a step further. They are now asking the public, including “civic hackers,” to analyze and augment the data, or to “mash it up” with other public data sets. And then tweet it at “#CFPBdata.” To me, this just exacerbates the reputation risk issues associated with the consumer complaint database.

But wait, there’s more. On Thursday April 4^th, the CFPB announced in a blog post that they are now accepting complaints regarding remittance transfers:  

“Every complaint we receive helps us understand the challenges facing consumers, and they inform and shape our priorities.

Reading your complaints about money transfers will complement work we have already started in this area, including issuing a rule on international money transfers, which will include a new set of protections for consumers who send money internationally.”

As if the rulemaking process for the final rule on remittance transfers hasn’t been difficult enough already, the CFPB is now soliciting complaint data on remittances, and who knows where that will lead. To me, this feels like throwing gasoline on a wild fire. But I digress.

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Iceland Photos, Part 2. On a more cheerful (less rant-filled) note, I thought I’d share a couple more photos from my trip to Iceland. Have a great weekend!

My brother and I at Gullfoss.

 

Skógafoss!

CFPB Sharing Complaint Data; Unverified Complaints; Feedback on NCUA Process

Written by Steve Van Beek

Back in mid-December, the CFPB announced it would be sharing consumer complaint data with state regulatory agencies.  They also note that this is just the beginning:

"In the future, we’re planning on building ways to accept complaints and information from the agencies as well, and to make the data available to other federal agencies, state attorneys general, local agencies, congressional offices as appropriate, and other governmental organizations like the California Monitor (a program of the California Attorney General) and the Office of Mortgage Settlement Oversight."

The announcement then goes on to provide a summary of the CFPB's complaint process:

"What happens when I file a complaint?

When a consumer files a complaint, we screen it to make sure that it’s complete and not a duplicate of another complaint we’re already working on for that consumer. Next, we send it to the company in question and ask them to reply to the complaint within 15 days and expect them to close all but the most complicated complaints within 60 days. After the company responds, we publish a selection of the data (with information identifying the consumer removed) in our public Complaint Database."

You'll easily notice that there is no verification process.  And, the Complaint Database's disclaimer doesn't exactly jump off the page.  Of course, this is an issue we've discussed over and over on the blog - so much so that we have a Member Complaints category.  

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Initially, it is important to remember that credit unions under $10 billion are not included in the Consumer Complaint Database.  The CFPB will forward any complaints from these credit unions to NCUA and credit unions will need to follow NCUA's procedures for responding to member complaints (more on this at the end of the blog post).  

Unverified Complaints.  So, what is the big deal with unverified complaints?  The reputation risk issue is one that cannot be ignored.  In this age of viral media - where a simple complaint or issue can fly through blogs, Facebook, Twitter - it is much harder to correct inaccurate information.  Sometimes, once the story is out there, it is....well, out there.  

But, there is another angle that could be even more dangerous.  The CFPB's Annual Report on Student Loans and the companion report - The Next Front? Student Loan Servicing and the Cost to Our Men and Women in Uniform - both use consumer complaints as a focal point to help show the current regulations or enforcement is insufficient.  

The latter quotes directly from consumer complaints, for example:

        
That comes from page 5 of the Report.  An earlier quote includes this footnote:  "This report cites information from specific complaints submitted to the CFPB. In these cases, the consumers have provided consent to include the details of their complaints."

Again, there is no mention of verification of the complaints.  I'm interested, was the rate incorrect?  We don't know.  But, the CFPB is implying it was by including one side of the story.  Remember:  The institution - whichever institution this was from - is prohibited by privacy laws from providing any information about the member's account.  So, we have the one side of the story.

Of course, I'm not saying these complaints are not true.  I'm just saying they are unverified (if they were verified, the CFPB should include that information).  

And, I'm not saying that institutions always do everything correctly.  For example, if this complaint is accurate - the institution has a lot of work to do:

"According to a complaint received by the CFPB, one borrower had six loans with a servicer, two of which had interest rates above six percent and four of which had interest rates below six percent. Instead of reducing the interest rate on the two higher-rate loans to six percent and leaving the four lower-rate loans untouched, the servicer simultaneously increased the interest rate on the lower-rate loans up to six percent."

Or, it could have been a mistake that was quickly corrected by the institution.  We just don't know.

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The New Cycle?  The reason I bring this up is that this seems to be the start of a new type of regulating that credit unions need to be aware of.  Or, at the least it is a new type of justifying the need for new regulation.  

Think about it.  The CFPB is soliciting consumer complaints (remember the flashing red "complaint button" on their first website?)  Then, they write a report (usually to Congress) using the complaints to argue there are issues that need to be corrected.  There might also be testimony to explain the report and what they've found.  After that?  Well, it might just be that the reports help build the case for a new regulation (or a new law from Congress).  All with unverified consumer complaints.  

At this point, we don't know.  But, the CFPB seems to be falling short of their data-driven analysis goal:

"The CFPB is a data-driven agency. We take in data, manage it, store it, share it appropriately, and protect it from unauthorized access. Our aim is to use data purposefully, to analyze and distill data to enable informed decision-making in all internal and external functions."

And, remember - the new requirements that come from these new regulations or laws will not be limited to credit unions with more than $10 billion in assets.  The new requirements will apply to everyone.  

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NCUA Complaint Process.  Taking a little different angle here.  We've detailed the NCUA Complaint process a couple of times on the blog.  Most recently here and here.  What we are interested in from blog readers is if there are areas NCUA could improve?  If so, please let us know.  We'll be sure to raise the issues with NCUA and see if some of the issues can be smoothed out.  

More on the CFPB's Strategic Plan for 2013-2018

Written by Steve Van Beek

Last Friday, we blogged on the CFPB's Strategic Plan for 2013 through 2018.  Today I wanted to review a couple aspects of the plan.  Initially, it makes sense to take a step back and look at the structure of the Strategic Plan:

• 4 strategic goals that outline what we aim to achieve
• 11 desired outcomes in support of our goals
• 25 strategies that state the actions we will take to accomplish our outcomes
• 27 performance measures that we will track against specific targets in order to assess our progress toward achieving our outcomes
• 4 performance indicators that we will track and use to assess progress toward achieving our outcomes. Unlike performance measures, indicators do not reflect targets

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Consumer Complaint Volume.  We blogged numerous times about the CFPB's Consumer Complaint Database and the lack of verification of complaints (as well as the CFPB's ineffective disclaimer).  

With this in mind, it was very disheartening to see this performance measure regarding consumer complaints:

"COMPLAINT VOLUME:  Number of consumer complaints handled"

Not to beat a dead horse, but why should the performance measure be quantitative rather than qualitative.  Shouldn't the measure relate to whether or not the submitted complaints were, in fact, valid?  Are consumers protected if the complaint volume increases?  Or are consumers protected if valid complaints are submitted and addressed?  

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Regulation Reviews.  Another interesting performance measure is the CFPB's completion of their review of existing regulations:

"% OF ON-SCHEDULE REGULATION REVIEWS:  The percentage of five-year regulation reviews completed on schedule"

If the CFPB's current streamlining initiative is any indication, the CFPB has put reducing regulatory burden very low on their priority list.  Hopefully they will place a greater focus on this issue in the future.  After all, credit unions (and the super-majority of other entities offering financial products and services) want to comply.  However, they are often faced with extremely complex or severely outdated regulations which make the process much harder than it needs to be.  

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Of course, there is much more information in the Strategic Plan and I encourage you to share this with your management teams and Boards.  

CFPB Report on Private Student Loans

Written by Michael Coleman, Regulatory Compliance Counsel

On Monday we blogged about a report on private student loans released by the CFPB's Student Loan Ombudsman. Today we would like to take a closer look at some of the details of the report. The report indicates that the current outstanding student loan debt is now over $1 trillion, with private student loans accounting for more than $150 billion (15% of the debt).  Furthermore, there are at least $8 billion of private student loans in default, representing more than 850,000 individual loans.  Student loans have now surpassed credit cards as the largest source of unsecured consumer debt. 

The report highlights and summarizes the information and complaints received by the CFPB concerning the student loan marketplace. The CFPB received approximately 2,900 complaints and other submissions from consumers concerning private student loans, the vast majority of which (95%) were about loan servicing. The report summarized some of the issues borrowers identified in their complaints:

"Inability to speak with personnel empowered to negotiate a repayment plan.  By far, the most common concern communicated by borrowers has been the difficulty negotiating a repayment plan with their servicer in periods of unemployment, underemployment, or financial hardship.  Many borrowers report frustration that they are unable to identify appropriate personnel that can make a determination about their repayment options.

Inability to refinance. Many student loan borrowers have a limited credit history when applying for a private student loan— and their interest rate reflects a high level of risk.  But as borrowers build a credit profile, graduate, and earn income, they are often unable to refinance existing student debt at a lower rate— in stark contrast to the market for mortgage refinance products. We have heard from borrowers who say they are looking for loans with more attractive terms, but many have been unable to take advantage of today’s historically low rates. 

[…]

Inability to access repayment plans previously advertised.  Many private student loan borrowers are able to enroll in alternative repayment arrangements included in the terms and conditions of their loans.  However, some borrowers note that enrolling in a new repayment arrangement is a difficult process.  Some servicing personnel may not be fully aware of all policies or incentive plans available to private student loan borrowers. "

The report also featured a discussion from the CFPB Student Loan Ombudsman on the issues identified in the complaints. One point raised was that the complaints received concerning student loan servicing bore a striking similarity to the complaints received concerning mortgage loan servicing. Another focused on the difficulty that borrowers face in modifying or refinancing student loans, and that the CFPB would welcome "creative efforts by lenders to help borrowers restructure their debt prior to or after default."

In the discussion the CFPB Student Loan Ombudsman had this to say about credit unions' participation in the private student loan market: 

"Community Banks and Credit Unions

A number of leaders from small financial institutions have expressed interest in developing longterm relationships with young customers but note that many of them are unable to enter the mortgage market due to their student loans.  One way that small financial institutions might assist younger customers to get closer to homeownership is to offer products that allow them to refinance any student loans they might have with rates in excess of their perceived repayment risk.  Small financial institutions might even be able to assist customers worried about falling behind on student loans by offering products that might allow them to be successful.  

The CFPB received very few complaints from borrowers with private student loans from small financial institutions.  Increased participation by small financial institutions might benefit the market." (emphasis added)

The report notes that 87% of the complaints were directed at just 7 companies (take a look at Table 2 on page 5 of the report), which is not surprising considering the concentration of the market. However, as the report indicates, the CFPB received very few complaints from borrowers with private student loans at credit unions, and that increased participation by credit unions in the private student loan market might be beneficial. 

The CFPB also released a fact sheet and press release regarding the report. 

CFPB Report on Private Student Loans; CFPB Remittances Webinar; NAFCU's Offices Closed

Written by Steve Van Beek

We'll keep this blog post brief as we’ll have additional information on the CFPB reports in future blog posts.

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Private Student Loan Report.  On October 16th, the CFPB issued a report on private student loans.  Here is from the press release:

"Today’s report, which was mandated by Congress, analyzed approximately 2,900 private student loan complaints, comments, and other submissions and input from borrowers. The report found that roughly 95 percent of the complaints are about loan servicing – when borrowers try to pay back their debt or are unable to pay."

The report is available here.  A fact sheet is available here.   

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Student Loans and Servicemembers.  On October 18th, the CFPB issued a report on student loans and servicemembers.  Prominent in the report were discusses of student loans and the SCRA:

"Many servicemembers navigate hurdles that may be unnecessary in order to receive the SCRA interest rate cap. Once a borrower has qualified for this interest-rate cap, the SCRA requires the servicer to continue to provide this benefit for the duration of the servicemember’s time on active duty, as reflected in the servicemember’s orders. We have received complaints from servicemembers, on active duty for multiple years, who reported that they were told that their interest-rate cap would expire annually, and were subsequently required to submit  additional orders in order to retain this benefit."

The report is available here.  The CFPB also released a Guide for Servicemembers with Student Loans.  

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CFPB Remittances Webinar.  If you missed the CFPB's webinar on remittances, you can view the archive here (slides are here).  The Small Entity Compliance Guide is also available.

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NAFCU Closed.  NAFCU follows the Federal Government Operating Status and our offices will be closed today due to Hurricane Sandy.  NAFCU Members:  If you have compliance questions, please email us at compliance@nafcu.org.  If you call, please leave a voicemail and we'll get back to you as soon as we can.   

For those in and around the Hurricane area, be safe!

CFPB Consumer Complaint Database Updates

Written by Michael Coleman, Regulatory Compliance Counsel

We previously blogged about the CFPB’s Consumer Complaint Database on a couple of occasions, highlighting the (relatively ineffective) disclaimer at the top of the page among other things. In the wake of the release of the CFPB Consumer Complaint Database, we also discussed member complaints and the reputation risks associated with the nature of viral media, NCUA’s member complaint procedures, and supervisory committee complaint procedures.

On October 10^th, 2012, the CFPB announced that its Consumer Complaint Database left the beta stage. The CFPB blog had this to say about the move out of beta:

“While we will continue to expand functionality, data fields, and the “look and feel” of the database, after performing for three months as designed and without incident, the database is no longer a beta product.”

Another important update to the Consumer Complaint Database is the addition of consumer credit card complaint data going back to December 1, 2011. The Complaint Database previously contained only those credit card complaints received by the CFPB on or after June 1, 2012.

Also, the CFPB has reiterated its intention to include other financial products in the Consumer Complaint Database, from the blog post:

“One potential area for database expansion is the inclusion of additional products and services. Over the summer we asked for public comment on this idea and got a wide range of comments from a range of interested stakeholders. We are in the process of evaluating those comments and anticipate a final Bureau decision in early 2013.”

The CFPB’s notice for public comment (referenced in the quote above) outlines the CFPB’s rationale for expanding the database to include other financial products services in addition to credit cards. NAFCU submitted a comment letter to the CFPB expressing its continued concerns that the release of unverified complaints to the public poses serious reputation risk issues to credit unions given the nature of viral media and the speed at which information is disseminated, and that this expansion will only compound those concerns. This comment letter echoes NAFCU’s previous comment letter regarding the Consumer Complaint Database.

Note that the database will only contain information of credit unions directly supervised by the CFPB, those with over $10 billion in assets, and that NCUA has not expressed any intention to create a similar database. However, if a member of a credit union with less than $10 billion in assets submits a complaint to the CFPB, the CFPB will forward the complaint to NCUA's Office of Consumer Protection for resolution according to NCUA's procedures. 

Where is the Rest of the Story?

Written by Steve Van Beek

The CFPB has started to regularly provide snippets of consumers they've helped following a complaint.  The CFPB has been posting these on its blog using the tag - Consumer Stories.  

One of these stories features Greg from Michigan.  And here is the story posted on the website:

"Greg, a 39-year-old insurance adjuster from Michigan, whose credit rating was damaged after a bank failed to tell him that an account with which he was associated was in arrears.

Greg added his name to his 71-year-old mother’s checking account after he helped her move into an assisted living facility. Six months passed without Greg getting any statements or hearing from the bank. Little did he know, however, that his mother had written a check and the account was racking up big fees because its balance had fallen below zero. He found out about it when he checked his credit report and saw that he owed a collection agency $469.

Greg paid the bill but his credit was harmed and he says the bank wouldn’t help. After the CFPB got involved, the bank apologized for their error, called off the debt collector, and had Greg’s negative credit record removed."

Now, you may have the following questions (and I'm sure there are many more):

• Where were the periodic statements being sent?
• Did Greg change the mailing address when he helped move his mother into an assisted living facility?
• Did Greg change the mailing address for the account when he added himself to the account?
• Was the mother receiving any information or correspondence from the bank?
• If Greg wasn't receiving any information from the bank, did he try to contact the bank?
• Did Greg try to access the account online?
• Did his mother tell him about the check she wrote (remember they are both joint on the account)?
• How does removing the negative credit record from Greg's account (even though it was accurate) improve the reliability of the credit reporting system?  Aren't creditors required to report accurately?  

Unfortunately, the CFPB has provided only a portion of the story.  The part that makes Greg look innocent and the bank at fault.  Of course, this might actually be true but there is no way to know without additional information.  And, it is quite sad to see the CFPB pushing out these partial stories trying to paint financial institutions as cold-hearted when there is most likely plenty more to the story.  So, to the CFPB - where is the rest of the story?

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I'm not the only one who noticed this one-sided story.  Kevin Funnell from the Bank Lawyer's Blog has a wonderful take on the CFPB's partial stories.  If you like Kevin's blog - and his snarkiness - you are in luck as he'll be our keynote at our 2012 Regulatory Compliance Seminar in Seattle.  The keynote presentation has a wonderful title - What Compliance Officers of "Good CUs" Can Learn from "Bad Banks".  

Supervisory Committee Complaint Procedures; On-Demand Webcasts

Written By Michael Coleman, Regulatory Compliance Counsel

Last month in the wake of the CFPB’s new Consumer Complaint Database, we blogged about member complaints and reputation risk, and NCUA’s member complaint process. Today’s post is the last in the series, and we want to talk about a credit union’s Supervisory Committee complaint procedures.

NCUA's Division of Consumer Compliance and Outreach (CCO) is responsible for the management of member complaints received by NCUA. NCUA Letter to Credit Unions 11-CU-17 details the responsibilities of CCO and also outlines NCUA's process for handling member complaints, which it states are in accordance with section 4.12 of the Supervisory Committee Guide. 

NCUA stresses that a member should try to resolve the issue directly with the credit union before submitting a complaint to NCUA. NCUA also directs members to submit complaints directly to a credit union's Supervisory Committee if the member feels the credit union is unresponsive to their complaint.

When NCUA does receive complaints, NCUA refers the matter to the credit union’s Supervisory Committee for investigation. The Supervisory Committee Guide outlines in detail the investigation procedures which the Supervisory Committee is expected to follow. These procedures start on page 4-10 and include numerous steps the Supervisory Committee should take in the investigation, including these highlights:

“(g) Interview appropriate credit union officials and/or employees.

[…]

 (i) Determine the validity of the complaint.

• Do not rely on the credit union’s manager or employees to do the investigation for the committee.  You should obtain all information firsthand, where possible.  Try to determine what actually happened, rather than obtaining various versions of what happened.

• You should not initiate a joint meeting between the complainant and the credit union officials as a means of resolving disputes or expediting the investigation.  This is often counter-productive and may intimidate the complainant.  You act as a liaison between members and management when disputes arise.

• Remember that no one likes to be investigated.  Credit union officials and employees will often be defensive and complainants may also be antagonistic.  You will need to be very skillful and tactful in obtaining the necessary information without alienating any of the parties involved.

j) Work with the officials to develop plans to correct any improper, unfair, or discriminatory practices, if applicable, or make appropriate recommendations.

k) Have corrective action implemented or obtain agreements from appropriate credit union officials and/or employees they will make corrections within a specified time.” (emphasis added)

From a review of the procedures, it is apparent that the Supervisory Committee is expected to complete a thorough, independent and impartial investigation into member complaints. As you can see from the highlighted sections above, while the credit union officials and employees are not expected to conduct the investigation, they are expected to facilitate the investigation. Working cooperatively with your credit union's Supervisory Committee when they are conducting an investigation into a member complaint provides another opportunity to help manage reputation risk. 

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NAFCU's Interest Rate Rule Webcast. With the upcoming compliance deadline of September 30, 2012, for NCUA's final rule on the required  interest rate risk policy and program, now is the perfect time to order NAFCU's May 24th, 2012 webcast: A Detailed Look Inside NCUA's New Interest Rate Risk Rule, which is available on-demand here. All of NAFCU's prior webcasts are available for order on-demand, you can find the event list here.