Posted by Anthony Demangone
It may be shocking to some, but not all compliance issues touch upon the Credit CARD Act! With that in mind, here are some things that have been kicking around my inbox that I wanted to share.
Red Flags. The FTC has delayed enforcement of the Identity Theft Red Flags Rule, again. This time until November 1. The delay will give state-chartered credit unions additional time to comply. Federal credit unions? No such luck. Our compliance deadline was, and still is, November 1, 2008.
NCUA Prohibition Orders. NCUA has issued its most recent bunch of prohibition orders. These orders effectively ban individuals who allegedly did bad things from working in our industry. They can be useful training tools to remind folks that the danger of embezzlement always is with us.
Another Reg Z change. On Friday, the Fed published final rules to implement portions of the Higher Education Opportunity Act. The compliance date will be 6 months after the final rule is published in the Federal Register, which should be shortly. For those who do not want to page through the 234 page rule, here's a link to a Fed Press Release that gives a very high-level overview.
Check processing changes. For those involved with Regulation CC and check holds, you've notice a ton of check processing restructuring at the Fed. Here's a Fed document that updates recent changes and gives a view to the future.
Foreclosures and tenants. The FDIC issued a consumer affairs letter to remind banks of a new law that protects tenants from eviction due to foreclosures. If your credit union does real estate lending, I'd give this a read.
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