Posted by Anthony Demangone
I hope everyone enjoyed their long weekend. Winter appears to be loosening its grip on the Washington, D.C. area. There's nothing like the sun on one's shoulders to put a skip in your step. Of course, by just thinking that out loud, I've ensured that we'll have a terribly cold spring. Here are a few things to kick off the week.
Consumer complaints. Last week, NCUA’s Chairman Debbie Matz and senior NCUA staff held a Webinar that covered a range of timely issues. One of those concerned NCUA’s practice of handing consumer complaints. As you may know, NCUA has established a new Office of Consumer Protection, which, among other things, will handle member complaints. Previously, after receiving the complaint, NCUA would contact the credit union and ask it to reply to the member and copy NCUA. This practice has now changed. Now, after receiving a complaint, NCUA will contact the credit union (specifically, the credit union’s supervisory committee) and ask that it responds to NCUA’s office of consumer protection. This is an important change and credit unions should be aware of it.
Archives. I'm embarrassed to pass along something that I learned about NAFCU's own compliance blog. Check out this archives page, which provides archives back to the beginning of the blog, as well as links to each of the blog's categories. Here's how the conversation went.
Steve: Check out this archive page.
Anthony: That's on our blog?
Steve. Yes.
Anthony. Cool.
That's right - nothing gets by me.
Sale of non-deposit investments. NCUA has published a legal opinion letter, which is their response to NACUSO on a number of issues related to NCUA's recent guidance on the sale of non-deposit investments.
SCRA Notice. HUD has updated its SCRA notice.
HPML. The Bankers Compliance Consulting Blog has a nice post on HPMLs and how the issue of truncating versus rounding can make a big difference.
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Happy to say that I knew about your archives page but no happy to say that I do not recall anything about posting an SCRA notice like the one in the link. Are we required to post this in, say, our branches? If so, I need to find out if we are doing that.
Posted by: Joyce | February 22, 2011 at 01:23 PM
This web page from HUD spells out what you need to do:
http://www.hud.gov/offices/hsg/sfh/nsc/qasscra1.cfm
Servicemembers Civil Relief Act Notice (Mortgagee Letter 2006-28)
Pursuant to the statutory amendment, HUD has developed, in consultation with the Departments of Defense and Treasury, the form for the required notice of servicemember rights (Attachment 1, SCRA Notice Disclosure). All mortgage loans, including conventional mortgages and mortgages insured by HUD are subject to the notification requirement that became effective June 5, 2006. The notice must:
Be sent to all homeowners who are in default on a residential mortgage;
Include the toll-free military one-source number to call if servicemembers or their dependents require further assistance (1-800-342-9647); and
Be made within 45 days from the date a missed payment was due, unless the homeowner pays the overdue amount before the expiration of the 45-day period.
Posted by: Anthony Demangone | February 22, 2011 at 01:32 PM