NAFCU Compliance Blog

NCUA to Cease Paper Mailings - Sign-Up for NCUA Express; Google Reader Ending Service on July 1st

Written by Steve Van Beek

Last week Bernadette highlighted the May 2013 NCUA Report. On the very last page was this notice:

"NCUA will stop mailing Letters to Credit Unions and other regulatory alerts as part of its ongoing efforts to reduce operating costs and become more efficient.

NCUA CU Express recipients automatically get the latest regulatory guidance and letters. All credit unions CEOs and Board Chairmen with emails provided in the CU Profile system are automatically subscribed to NCUA CU Express, and should currently be getting all regulatory letters or alerts.

NCUA CU Express emails are mandatory for credit union CEOs and Board Chairmen, while the separate, but similar NCUA Express is open to the public and subscriber-driven. In addition to regulatory alerts, you can sign up and receive NCUA’s monthly newsletter, The NCUA Report, legal opinions, press releases and more, using the NCUA Express system.

For more information about NCUA Express and to subscribe, free of charge, visit http://go.usa.gov/TDsC."

If you haven't already, consider signing up for the NCUA Express. At a minimum, be sure to pass this along to your colleagues in case they rely on the paper mailings. And, while you are at it - make sure your CEO and Board Chairmen's emails are current so they are getting all the information from the NCUA CU Express.

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Google Reader. Many blog readers use an RSS aggregator such as Google Reader. On July 1st, Google will no longer be supporting Google Reader - so it makes sense to begin the migration to a new RSS aggregator soon. Personally, I've switched over to Feedly (and since wondered multiple times why I didn't earlier). And, best of all - you can connect your existing feeds from Google Reader over to Feedly. Of course, there are additional alternatives as well. 

If you're wondering what RSS is, Wikipedia has some good information. In short, RSS feeds (and an RSS aggregator) allow you to receive updates to a particular blog (or other website) when they occur. If your email inbox is overflowing with blog posts and other resources, having an RSS aggregator can help you stay on top of the news you need without it cluttering up your inbox.  

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Asheville, North Carolina. Last week, Erin and I had the chance to head down to Asheville for NAFCU's Board of Directors Conference. Asheville is a special city for us as we got engaged there over Labor Day weekend in 2010.

Biltmore Gardens

Chimney Rock State Park, Chimney Rock, NC. And, that is Lake Lure in the background. Erin informed me numerous times (plus or minus 20) that Lake Lure was where "Dirty Dancing" was filmed.

Cyber Threats; SCRA; Fannie Mae Resources; Economic Update; Mortgage Servicing Transfers

Written by Steve Van Beek

Below are couple of tidbits for your Tuesday.

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NCUA Risk Alert on Cyber Threats.  NCUA issued Risk Alert 13-Risk-01 on steps credit unions should take to protect against Distributed Denial-of-Services (DDoS) attacks.  In recent months, these attacks have ticked up at financial institutions – including credit unions.  Be sure to pass this Risk Alert along to those in charge of risk management and information technology at your credit union.    

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CFPB “Hit or Myth” on SCRA.  The CFPB had a recent blog post on various confusing issues related to servicemember protections under SCRA.  These “Hit or Myth” questions and answers might be useful for internal SCRA training.  For more CFPB information on servicemembers, check out this page.    

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Fannie Mae Loan Quality Resources. If your credit union sells loans to Fannie Mae, be sure to check out their new resources regarding Loan Quality.  The webpage includes resource guides as well as free webinars to help understand Fannie Mae’s procedures.  Be sure to pass along the resource page to others at your credit union. 

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NCUA’s February Economic Video.  NCUA’s latest economic video is now available for viewing on YouTube.  Each month, NCUA’s Chief Economist John Worth provides an overview of the economic market and how it impacts credit unions.  These are great videos to include in strategic planning or board sessions as NCUA comes directly to you – via YouTube – each month with an economic update.  

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CFPB Bulletin on Mortgage Servicing Transfers.  In addition to changing nearly all the mortgage servicing requirements in January, the CFPB has mortgage servicing transfers in their crosshairs.  In mid-February, the CFPB announced their intent to “closely monitor transfer activity” by mortgage servicers.  In conjunction with the announcement, the CFPB issued Bulletin 2013-1 which provides specific information regarding the CFPB’s detailed focus on mortgage servicing transfers.  

New NAFCU Blog, Same Approach

Written by Anthony Demangone 

When my father dropped me off at McKean Hall for my freshman year at Penn State, I knew I wanted to be a journalist.  I quickly joined the college newspaper and started writing.  I never found stories about intrigue and politics interesting to write.  Rather, I focused on things that interested me.  

I somehow got sidetracked on my road to the Pulitzer Prize. Life happens.  But my love of writing never wore off.  That’s one of the reasons I started the NAFCU Compliance Blog back in 2007.  

But life happened…again.   When I took on the role of NAFCU COO, I handed off this blog to Steve’s capable hands.  

Well, the addiction has overtaken me yet again.  As Steve mentioned a few weeks ago, I’ve started a new blog – Musings from the CU Suite.  What’s the new angle?  Work and management are tough.  But there’s a ton of good information out there about how to be better at both.  My new blog will attempt to bring the best of all of that to you.  

I hope you consider wandering over to sign up for the blog.  It would be great to have you join the conversation.

Now, I did write along those lines a wee bit back in the day.  Here are some of those old posts, which I hope you find useful.  

• Just how did my view of compliance change now that I’m NAFCU’s COO?
• A good compliance officer should try to read the tea leaves.
• In an age of Google, Facebook, Twitter, and iPads, don’t forget the research power of picking up the phone. 
• The art of making decisions when you are “off the grid.”
• My ode to compliance officers.  

Have a great week, guys.  

This and That: CIiCU; SCRA; NAFCU Comment Letters & Finals

Written by Steve Van Beek

The latest Current Issues in Credit Unions podcast is now available.  Rob Rutkowski does a great job with these monthly podcasts and both he and Katherine Weber will be down at NAFCU's Regulatory Compliance Seminar in late October to do a live taping of the podcast.  

Speaking of Seminar........the agenda for this year's Seminar is now out - take a look for yourself.  We also have time set aside for "Compliance Hot Topics" as we all know there is a good chance for some regulatory shenanigans between now and October.  During those sessions Sarah and I will cover some of the latest rules and guidance issued.

Also, keep in mind that anyone can attend: NAFCU member; non-member; attorney; consultant; vendor - you name it - we'd love to see you in Florida.  Diversity of background and viewpoints are terrific things.   

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A couple months back, Buckley Sandler delivered a webinar on SCRA issues.  The webinar and slides are here and might prove useful to review SCRA issues at your credit union in anticipation of increased scrutiny.

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NAFCU has sent a couple of comment letters to NCUA recently.  One was our comment letter on Incentive-Based Compensation and the other our comment letter on NCUA's Proposed Voluntary Prepayment plan.

Our Regulatory Affairs team was also busy publishing Final Regulations on the Noninterest-bearing Transaction Account rule and the NCUA's Accuracy in Advertising rule.  NAFCU Members can access those Finals and others here.  

FTC Strikes Again

Posted by Steve Van Beek

Yesterday, the Federal Trade Commission (FTC) announced a settlement with Sony BMG Music Entertainment for violations of the Child Online Privacy Protection Act (COPPA).  Sony BMG agreed to pay $1 million to settle the alleged violations which is the largest penalty in a COPPA case.  Here is some information on the alleged deficiencies in Sony BMG's website maintenance:

"The company operates over 1,000 Web sites for its musical artists and labels. Sony Music requires users to submit a broad range of personal information, together with date of birth, in order to register for these sites. On 196 of these sites, Sony Music knowingly collected personal information from at least 30,000 underage children without first obtaining their parents’ consent, in violation of COPPA. Many of these sites also enable children to create personal fan pages, review artists’ albums, upload photos or videos, post comments on message boards and in online forums, and engage in private messaging. In this way, children were able to interact with Sony Music fans of all ages, including adults."

But, here might be the clincher - they did not follow their own privacy policy:

"The FTC’s complaint also charges Sony Music with violating Section 5 of the Federal Trade Commission Act by falsely stating in its privacy policy that users who indicate that they are under 13 on its Web site registration pages will be restricted from participating in Sony Music’s web page activities. In fact, Sony Music accepted registrations from children who entered a date of birth indicating that they were under 13."

Here is a link to a May blog posting by Anthony that discusses COPPA and contains links to FTC and NCUA guidance regarding COPPA compliance. 

Have a safe, warm weekend. 

NCUA Moving to Online 5300 Call Reports in Late 2009

On Tuesday, NCUA posted frequently asked questions (FAQs) related to their future shift to online 5300 Call Reports.  The switch to online reporting is scheduled for late 2009 (natural person credit unions) and 2010 (corporate credit unions).

The first five Q&As provide the basic details (there are 22 total Q&As):

"1. What changes are being made?
NCUA is developing an online (web-based) environment for federally insured
credit unions to self-manage profile information, submit data, and receive
information from NCUA.

2. When do these changes take effect?
The new online profile and Call Report will be deployed in late 2009 for natural
person credit unions and 2010 for corporate credit unions.

3. What is the “online profile”?
The online profile will include information that NCUA maintains about a credit
union that infrequently changes. For example, the credit union address(es), phone
number(s), list of officials, hours of operation, etc. Credit unions will be able to
change certain fields online to provide a real-time environment for updating
contact information.

4. Will I be required to use the online system?
Yes. All federally insured credit unions with access to the Internet will be
required to submit their data online. Hardship provisions will be made for
computer disruptions during the upload period.

5. I am a manual credit union. How does this affect me?
Policies will be established addressing manual credit unions and submission of
their data. NCUA will release more information on this topic at a later date."

Additionally, the Report of Officials (ROO) will be moving online as well.  View the FAQs to get answers to your questions and look for more info from NCUA as the shift gets closer.

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The Compliance Guy will make his long-awaited return on Tuesday.  Thanks for being kind to Sarah and me.

Enjoy the first weekend of college football.  Have a safe, relaxing holiday weekend.      

VISA Pilot Program to Provide Alerts to Wireless Devices

I must admit, I'm one of those people.  You know - the ones who are constantly checking their account balances and transactions online.  What can I say, I like confirming that my automatic payments have been processed and my credit card transactions are correct.

Needless to say, I was pretty stoked to read this NAFCU Today article highlighting the new pilot program being tested by VISA.  The program will use text messages and emails to alert cardholders of activity on their accounts. 

Here is more information from the VISA press release:

"Based on Visa's state-of-the-art transaction authorization system, and its ability to analyze and conduct risk score transactions "in-flight," the service allows Visa cardholders to set thresholds that will trigger a transaction alert. Alert types that Visa cardholders may choose in the pilot include:

    * cash withdrawal from an ATM machine;
    * a transaction initiated cross border;
    * an Internet or telephone transaction and
    * a transaction that exceeds an amount that has been chosen by the cardholder.

Through the alert received via email or SMS text, cardholders can verify the transaction details, and if the transaction appears to be irregular, can immediately contact their bank to help stop further transactions on the card. The service is designed to help cardholders keep closer track of their transactions and spending levels as they go about their daily routine."

Sign me up.  I would love the ability to set a dollar threshold above which I would receive a text message or email.  Imagine the reduction in fraud-related charges if your member was notified immediately of a transaction they did not authorize rather than reviewing (or not reviewing) their periodic statement.

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Looking for growth in the Generation X & Y markets?  The VISA press release includes information from a Pew Research Center study:

"more than 80 percent of consumers between the ages of 18 and 49 use their mobile devices to engage in activities such as sending text messages, taking pictures and accessing the Internet."

This study was conducted by the Pew Internet & American Life Project at the Pew Research Center and the full 12-page report would be a great read for strategic planning and marketing purposes.