NAFCU Compliance Blog

FTC Releases Top Consumer Fraud Complaints; Viva Las Vegas; The Diet

The FTC has released a list of the top consumer fraud complaints.  View the list here. 

Why should compliance officers care?  NCUA has indicated that credit unions should consider educational efforts regarding identity theft and fraud for their membership. (Letter to Credit Union 05-CU-18, Attachment).  This list provides the top 20 areas where consumers have been burned.  I think credit unions could build an educational program around that list.

***

Vegas, baby.  Vegas.  NAFCU will host a free educational session on Friday, February 29 in Las Vegas, Nevada.  Yours truly will hit as many topics as he can in roughly 2 1/2 hours.  The event is open to all credit unions.  So bring your questions.  Your compliance comments.  And your lucky rabbit's foot.

When: Friday, February 29, 2008
What Time: 8:30 – 12:00 noon
Where: Planet Hollywood Resort & Casino, Las Vegas, NV

Visit this link for additional details, including how you can sign up.

***

Current Weigh Loss: 11 pounds. 
Needs to Lose: 59.
Days until Wedding: 85.
Current Estimated Odds of Success:  Akin to the Pirates' chance of winning the World Series.

NCUA is...taking it to the streets; The Diet

NCUA just announced their 2008 schedule for credit union workshops.  They'll hold 20 training sessions across the U.S.A this year.  And you can't beat the price.  They're free. 

The sessions will cover the following topics:

• Update from Regional Management
• Future of NCUA 5300 Call Reports
• Common BSA Violations
• Evaluating Third Party Relationships – Due Diligence
• Modifications to the CAMEL Rating System
• Attracting and Recruiting Volunteers
• Expanding Credit Union Services Through Partnerships

You can read more about the workshops here.   They first workshop is March 15 in Raleigh/Durham, NC.

(And admit it.  Taking it to the streets?  You had that Doobie Brothers song in your head.  Didn't you.)

***

Current Weigh Loss:  9 pounds. 
Needs to Lose: 61.
Days until Wedding: 95.
Current Estimated Odds of Success:  ∞ to 1.

NCUA acts to keep usury ceiling at current level; Issues ANPR on Mergers and Conversions; The Diet

Yesterday, NCUA's Board voted 3-0 to keep the federal credit union loan interest rate ceiling at 18 percent.  The decision is effective March 10, 2008, and will remain effective for 18 months.  Read the approved draft board action memorandum here.   NCUA prepared a draft letter to credit unions about the issue.  Have a peek at it here.

Many people are not aware that the Federal Credit Union Act sets the maximum interest rate for federal credit unions at 15 percent, unless NCUA's Board establishes a higher rate after considering certain factors.  That's what NCUA did yesterday.  But these decisions are temporary, so NCUA must revisit the issue at least every 18 months.

***

NCUA also issued an ANPR regarding mergers and conversions.  NCUA is considering whether to issue regulations to govern the merger of a federally insured credit union into a mutual savings bank or a federally-insured credit union's conversion to a financial institution other than a mutual savings bank.  There are currently no NCUA regulations governing these types of transactions.   Read the ANPR here.  We'd love to have your comments.

***

For those who would like a follow-up to Rep. Barney Frank's Press Conference, NAFCU should have a story here about what he said.

***

Current Weigh Loss:  8 pounds. 
Needs to Lose: 62.
Days until Wedding: 107.
Current Estimated Odds of Success:   NASA's computers are still trying to compute the number.  Some guy called me from NASA and said they may need a bigger computer.

Due to this, shall we say, weight loss plateau, I've decided to do this.  This could get ugly.

Pandemics and Telecommuting; The Diet

NCUA and FFIEC guidance requires credit unions to plan accordingly for the effects of pandemics on their operations.   Many credit unions have indicated that they will utilize telecommuting in some form to help cope with pandemics.  But is the communications network up to the challenge?

Read a NAFCU Today article here that highlights the release of a detailed study on this issue.  From the story, NAFCU members will be able to download the study.   The study provides base assumptions and best practices for IT professionals, telecommuters, and the general public.

For those tasked with pandemic planning, it is a must read.  And if I could write poetry, I would write a poem describing how much I love people who are willing to share best practices.  (Oh, why not.)

Oh, best practices!
How I love thee, you  make
My job easier, by far

***

Current Weigh Loss:  7.4 pounds. 
Needs to Lose: 62.6.
Days until Wedding: 122.
Current Estimated Odds of Success:   1,000 to 1

Dieting is not complicated.  But it is very, very difficult.  Much like dealing with the affiliate marketing rule. 

NCUA Board Meeting Agenda, Prohibition Orders; The Diet

Here's the agenda for this Thursday's NCUA Board meeting.  No new regulations are on the table.

***

NCUA has issued six prohibition orders.  You may want to forward this info to HR, as these folks are not allowed to work at any federally-insured institutions.  Yes, that includes federal credit unions.

***

Here's the latest data. (And yes, I'll use decimal points if they work in my favor.)

Current Weigh Loss:  6.4 pounds. 
Needs to Lose: 63.6.
Days until Wedding: 150.
Current Estimated Odds of Success:  199 to 1

The FACT Act Strikes Again; The Diet

NCUA, along with other financial regulators, have issued proposed regulations to "help ensure the accuracy and integrity of information provided to consumer reporting agencies and to allow consumers to directly dispute inaccuracies with financial institutions and other entities that furnish information to consumer reporting agencies."

Read the NAFCU Today article about the proposal here.  Read NCUA's press release here.  Find the proposed regulations here.  The proposal has not appeared in the Federal Register yet.

***

NAFCU members:  NAFCU has posted its Final Regulation on NCUA's Purchase, Sale and Pledge of Eligible Obligations.  NAFCU members can access it here.

***

The Compliance Guy hates dieting.  Especially over Thanksgiving.  And his birthday.  And that's all I'm going to say about that.

Current Weigh Loss:  4 pounds. 
Needs to Lose: 66.
Days until Wedding: 162.
Current Estimated Odds of Success:  99 to 1

NCUA Tweaks Eligible Obligations Rule; Compliance Guy Decides to Tweak his Waistline

During yesterday's NCUA Board meeting, NCUA issued a final rule that adds a conflict of interest provision to its eligible obligations rule, which rests at 12 C.F.R. 701.23.  The eligible obligation rule governs how federal credit unions can purchase loans or groups of loans.   The conflict of interest provision is very similar to the conflict of interest provision in NCUA's general lending rule. 

With certain exceptions, the new rule prohibits federal credit union officials, employees, or their immediate family members from receiving, directly or indirectly, any compensation in connection with that credit union’s purchase, sale, or pledge of an eligible obligation under the provisions of §701.23.

Here's a link to the final rule.  It is effective 30 days after it appears in the Federal Register.  The Compliance Guy guesses that it will be published there very soon.

***

The Compliance Guy is getting hitched on May 10, 2008.    As part of my pre-nuptial duties, I've been visiting my future family members.  Recently, I visited with my future nieces and nephews.  The youngest nephew shuffled up to me with a broad grin.  In his three-year-old voice, he said the following.  "You're bald and fat."  I told him that he'd make a good consultant some day.

Ergo, the Compliance Guy is on a diet.  The goal?  To lose 70 pounds in 6 months.  Is this obtainable?  Likely not.  But as a compliance officer, the Compliance Guy is used to difficult goals with short deadlines.   Wish me well, folks.  Wish me well.

Current Weigh Loss: 2 pounds. 
Needs to Lose: 68.
Days until Wedding: 176.
Current Estimated Odds of Success:  100 to 1.