NAFCU Compliance Blog

Holiday News from the NCUA; Programming Note; Speaking of Holidays

Written by JiJi Bahhur, Director of Regulatory Compliance

With 2014 coming to an end, I thought I'd put on your radar some of the more recent items released by the National Credit Union Administration (NCUA) during this very busy holiday season.

MSB Exam Guidance from the NCUA.  For sake of not bogging you down on New Year’s Eve, I won’t be covering this guidance in any detail here (but we’ll be sure to do so in a very near future blog post).  What I do want to do is put it on your radar in case you missed it during the busy holiday season.

Just briefly, what is this guidance?  NCUA released Letter to Credit Unions 14-CU-10 (“letter”) to provide guidance to credit unions that provide or intend to provide account services to a money service business (MSB).  In the letter, it discusses what an MSB is, the potential risks posed by MSBs, and how a credit union can mitigate those risks.  Moreover, the letter advises credit unions to review the enclosed examiner guidance – Supervisory Letter No. 14-05 – because NCUA’s field staff have been provided this examiner guidance and will use it to evaluate credit unions that provide account services to MSBs.   

First 2015 Grant Round for Low-Income CUs.  With an application period between February 2 and March 3, 2015, NCUA is inviting applications for low-income credit unions interested in providing staff training or hiring interns through use of funds from the Community Development Revolving Loan Fund.  NCUA has stated that it will provide at least $360,000 in funding during this first grant round in 2015, which will cover more than 100 requests from low-income credit unions for internships or staff or volunteer training programs.  If you are designated as a low-income credit union, check out the NCUA’s announcement here for more information and how to apply.  

Latest Videos from the NCUA.  In the last couple of weeks, the NCUA has made available the following videos:

• NCUA Assessment Update - Stabilization Fund –posted on December 16^th, the video is based on information presented at the July 2014 NCUA open Board meeting. 
• New Economic Update Video – posted on December 23^rd, this video covers the latest economic activity, the 2015 economic outlook and the performance of federally insured credit unions during the third quarter.
• New NCUA Video Outlining Field of Membership Options and Strategies – posted on December 29^th, the video provides an overview of the various field of membership types available to federal credit unions and briefly identifies expansion and conversion opportunities available for each field of membership type.

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Programming Note.  NAFCU’s offices will close today at noon for the New Year and will reopen on Monday, January 5.  Happy New Year to you all! We’ll be back to blogging on Monday.

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Speaking of the holidays – my two-year old twins, Kyse and Ava, had a blast opening presents and going from house to house visiting family.  Some photos from the festivities:

Happy New Year to you all! 

With Major Changes in U.S. Policy, Cuba Sanctions to Be Eased

Written by Shari R. Pogach, Regulatory Paralegal

One of the biggest news stories to hit the airwaves recently was that of President Obama’s announcement of major changes in U.S. policy with respect to Cuba.  The key elements of the executive actions to re-frame U.S. relations with Cuba concern: 1) re-establishing diplomatic relations, including re-establishing an embassy in Havana; 2) easing the regulatory hurdles to travel to Cuba; and 3) expanding and authorizing trade and financing.  Financial institutions can expect changes in two areas as a result of the policy changes, remittances and correspondent accounts. 

Remittances 

Remittance levels will be raised from $500 to $2,000 every three months for general remittances to Cuban nationals (excluding certain officials of the government or the Communist party). Remittance forwarders, as well as donations for humanitarian projects or private businesses, will no longer require a specific license. 

Correspondent Accounts  

U.S. financial institutions will be permitted to open correspondent accounts at Cuban financial institutions to facilitate the processing of authorized transactions. 

The U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) has an entire webpage dedicated to Cuba sanctions with a number of resources including a reference brochure overview of Cuba sanctions.  OFAC has actually posted an FAQ concerning implementation of the policy change: 

“Q.  How will OFAC implement the changes to the Cuba sanctions program announced by the President on December 17, 2014?  Are the changes effective immediately? 

A.  OFAC will implement the Treasury-specific changes via amendments to its Cuban Assets Control Regulations. The Department of Commerce will implement the remainder of the changes via amendments to its Export Administration Regulations.  OFAC expects to issue its regulatory amendments in the coming weeks.  None of the announced changes takes effect until the new regulations are issued.” 

In addition, anyone looking for email updates on Cuba sanctions can sign-up here.

NCUA’s December Report Addresses Concerns about Liability Under the Ability-to-Repay-Rule; Impact of DoD Proposed Rule Webcast; Programming Note

Written by Victoria Daka, Regulatory Compliance Specialist

Compliments of the season! "It’s the most wonderful time of the year.”

On Friday, Brandy blogged about the Region III Report article from the latest NCUA Report. Today, I’d like to take a look at another article from the NCUA Report, which focuses on the Ability-to-Repay Rule. This article seeks to address the concerns about liability under the CFPB’s Ability-to-Repay Rule by indicating the reason for the “qualified mortgage” definition; extending leeway to credit unions to continue using their existing successful traditional relationship-lending approach; and, summarizing the three main categories of “qualified mortgages.”

As per the article, “Congress directed [the CFPB] to define a category of loans where lenders would have certainty that their loans comply with the rule, and where borrowers would have the greatest protections. So, [the CFPB] developed criteria for what are called “qualified mortgages.” In addition, this article informs credit unions that they may continue to utilize their successful traditional relationship-lending approach, regardless of whether the mortgagees are “qualified,” as there many loans that are not qualified mortgages, yet are fundamentally sound.  

 Furthermore, this article summarizes the three types of qualified mortgages: (1) the general definition; (2) the “GSE eligible” provision; and (3) the small-creditor provision as follows:

“General Definition. Any loan for which the consumer’s income and debt have been considered and verified with a debt-to-income ratio of 43 percent or less is a qualified mortgage.

GSE or Agency-eligible” Category of Qualified Mortgages. If a mortgage is eligible to be purchased, guaranteed or insured by one of several government-sponsored enterprises or certain government agencies—Fannie Mae, Freddie Mac, the U.S. Department of Agriculture and the Rural Housing Service—it is considered a qualified mortgage…

Small-Creditor Category of Qualified Mortgages. If your credit union has less than $2 billion in assets (adjusted annually for inflation) and your credit union and affiliates made 500 or fewer first-lien, closed-end mortgages in the prior year, then all mortgages you keep in portfolio are considered qualified mortgages.”

 The article is available in its entirety here.

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Webcast: How All Credit Unions Will Be Impacted by the DoD Proposed Rule

If you offer unsecured credit of any kind, then this webcast is a must-attend event—the proposed rule doesn’t just affect military-focused credit unions. The Department of Defense’s proposed rule would amend the Military Lending Act (MLA) to make the definition of “consumer credit” cover more credit types. Learn what you can do to prepare and protect your credit union with this strategic webcast.

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Programming Note. NAFCU's office will close at noon today and will also be closed on Thursday and Friday for the long holiday weekend. We will be back to blogging on Monday. Happy Holidays!

Credit Union Share Insurance Parity for IOLTAs

Written by Bernadette Clair, Senior Regulatory Compliance Counsel

I hope everyone had a wonderful weekend – and here’s a little good cheer for Monday morning!

Last week, President Obama signed H.R. 3468, the “Credit Union Share Insurance Parity Act,” into law, ensuring that federally insured credit unions have parity with FDIC-insured institutions for escrow accounts such as Interest on Lawyer Trust Accounts (IOLTAs). Share insurance parity for these accounts has been a key aspect of NAFCU’s five-point plan for regulatory relief for credit unions.

Previously, credit unions have been at a competitive disadvantage compared to banks because they could not offer the same level of insurance on lawyers’ trust accounts, since not all clients of a lawyer were members of the credit union that held the trust. Now, under the new law, these accounts are insured to the limit allowed by the Credit Union Share Insurance Fund. From NCUA’s press release:

“Credit unions now have parity with banks and, effective immediately, can fully insure lawyers’ trust accounts up to $250,000 for each owner of the funds, which they could not do before,” Matz said. “An attorney who is a member of the credit union where the trust account is opened now has a choice of financial institutions for that trust account. This enhances public confidence in both the banking and the credit union systems now that federal share and deposit insurance programs administered by NCUA and the FDIC are the same.” (My emphasis)

Matz also said NCUA will make changes to its regulations to fully conform to the Act.

December NCUA Report Discusses CUSO Rule; Introducing Nolan

Written by Brandy Bruyere, Regulatory Compliance Counsel

Since it is Friday, and I am a bit rusty on blogging, we will keep it rather short today. On December 10, The NCUA issued this month’s issue of The NCUA Report. While this issue largely focuses on NCUA budget issues, the Region III Report focuses on the CUSO rule which went into effect in June, 2014. This article aims to clear up “some confusion as to what the rule does or what is required from a credit union and its CUSO” by providing a summary of the rule’s main requirements:

• An extension, for consistency, of the CUSO rule to all federally insured credit unions. Prior to this change in November 2013, rules governing CUSOs only applied to federal credit unions.
• The requirement that a CUSO must agree to:
  • Prepare quarterly financial statements.
  • Account for its transactions in accordance with generally accepted accounting principles.
  • Obtain an annual financial statement audit by a licensed certified public accountant.

The Report also reminds credit unions that in addition to the CUSO reporting requirements, credit unions must continue to conduct risk assessments of their relationships with CUSOs. Here are questions the Report suggests credit unions ask when evaluating a CUSO relationship:

• Does the service provided by the CUSO benefit the existing members of the credit union?
• Does the CUSO conform to the requirement of primarily serving credit union members and not other interests or parties?
• Is a legal opinion needed to determine permissibility of the proposed structure of the CUSO?
• Is the investment in or loan to the CUSO a suitable avenue for revenue growth or expanded services for members?

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Introducing Nolan! I have been absent from blogging for a while because my husband and I welcomed baby Nolan in early October. Nolan was 9 pounds, 8 ounces at birth, good thing he came a few weeks early! Here are a few photos of our little guy, including one with his best dog buddy, Lemmy.

One-Year Extension of the SCRA’s Post-Service Mortgage Protections

Written by Eliott C. Ponte, Regulatory Compliance Counsel

On Friday, the House and Senate unanimously passed a one-year extension of the Servicemembers Civil Relief Act’s (SCRA’s) post-service mortgage protections.  See S. 3008. The amendment will extend a provision that ensures servicemembers who are serving in the armed forces are protected against losing their home for one year upon his or her return from active duty, if the mortgage was obtained before the servicemember was an active member of the military. 

Congress first extended the period of foreclosure protection under the SCRA in 2008.  Originally, the extension was for 90-days; however, in 2012, Senator Sheldon Whitehouse successfully extended the SCRA protection to one year.  The protection was set to expire at the end of this year, and the period of mortgage protection would have reverted back to 90 days.  With the passage of S. 3008, the provision was extended for one more year and will now expire on December 31, 2015. 

Compliance officers reading this blog are probably thinking, enough with the history lesson; what about the HUD-92070 form that accompanies the extended SCRA protection!  Unfortunately, there is no official word on this front; however, NAFCU anticipates the Department of Housing and Urban Development (HUD) to update the HUD-92070 form to reflect the most recent extension in the very near future.  When HUD does issue an updated HUD-92070 form, rest assured that NAFCU will sound the alarms to alert credit unions to start using the new form. 

NCUA Board Meeting; Regulatory Compliance School; A Little Taste of Vienna

Written by Shari R. Pogach, Regulatory Paralegal

The agenda for the National Credit Union Administration’s (NCUA’s) board meeting last week was a relatively short one with just three items:

1.  Final Rule, Parts 701 and 722 of NCUA’s Rules and Regulations, Appraisals.
2. Notice and Request for Comment, Economic Growth and Regulatory Paperwork Reduction Act      Review.
3. 2015 Corporate Stabilization Fund Quarterly Report.

Here we’ll just briefly discuss the new final rule regarding appraisals. The NCUA Board approved a new final rule to revise two of the agency’s regulations concerning appraisals. What’s changed? The final rule eliminates the now duplicative requirement for federal credit unions to make available a copy of the appraisal used in connection with a member’s application for a loan secured by a first lien on a dwelling to any requesting member/applicant. It also expands the current exemption for certain transactions involving an existing extension of credit. Under the expanded exemption, a federally insured credit union will be permitted to refinance or modify a real estate-related loan held by that federally insured credit union in a declining housing market, without having to obtain another appraisal, if there is no advancement of new monies or if there is adequate collateral protection even with the advancement of new monies. Finally, the rule also makes a minor technical amendment to the definition of the term “application.” The rule becomes effective 30 days after its publication in the Federal Register. 

Chairman Matz welcomed the final rule as credit unions will be able to more easily refinance loans without encountering unnecessary administrative burden. She also noted that these changes will bring NCUA’s rules into parity with the other banking regulators.

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NAFCU’s Regulatory Compliance School should be on every compliance professional’s “nice” list. Get comprehensive compliance training on what you need to know now, plus what’s coming up. Save $200 with code HOLIDAY when you register by January 9. Learn more.

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Vienna. Here are a few photos from my recent vacation.  Although it gets dark earlier in the day and is a little chilly and damp, Vienna is full of Christmas markets this time of year and with the lights, it is quite a charming city.  I thoroughly enjoyed Vienna and thought I’d share a little of my experience there with you. 

New Vienna and Gothic Vienna on Kärnterstrasse Shopping Street

The Reisenrad (ferris wheel) at Prater from Stephansdom’s North Tower – so cold!

Riding the Resisenrad – It’s only about 4:30 in the afternoon!

 
Rauthauspark (town hall) Christmas Market – where you drink Gluhwein to keep warm!

Christmas yummies

 
Saturday Christmas shopping on Mariahilfer Strasse

My Sachertorte and Melange – vacationing is such hard work!

Comment Letter Talking Points for DoD’s Military Lending Act Proposal; Recent Policy Changes to Military Allotment Process

Written by Quincy Enoch, Military Liaison

Hello and Happy Holidays,

The Holidays are fast approaching which means the comment period deadline for the Department of Defense (DoD) lending rule is approaching fast as well. As Mike and I noted in our November 21^st post, this rule is going to impact all credit unions by creating additional compliance burdens for all credit unions.

Understanding the impact the DoD proposed rule will have on the credit union industry, many of our members have expressed interest in sending comments to DoD. With this in mind, NAFCU has prepared a helpful guide to look to when preparing your comment letters. If you have any questions, please don’t hesitate to contact me at [email protected].

DoD rule talking points

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Additionally, I would like to mention a recent change to the military allotment process. According to DoD, as a result of abuses of the allotment system by predatory banks and retailers, Secretary Hagel has prohibited the use of allotments to pay for particular items (for only active duty troops). These items include:

  - Vehicles (e.g., automobiles, motorcycles, boats);

  - Appliances or household goods (e.g., washer, dryer, furniture);

  - Electronics (e.g., laptop, tablets, cell phone, television); or,

  - Other consumer items considered to be tangible and movable.

The policy change is with respect to new allotments and will not affect any current allotments. The prohibition will only apply to allotments started on or after the effective date, which is January 1, 2015. The policy change will not affect allotments to savings account, checking accounts, investments, mortgages or rent.

These policy changes were made under Secretary Hagel’s authority to make changes to the Financial Management Regulation (FMR) and did not require the typical rulemaking procedures. To enforce the prohibition, DoD will require servicemembers to certify under penalty of the Uniform Code of Military Justice (UCMJ) that the allotment is not being set up for the purpose of the purchase, lease or rental of personal property or payment towards personal property.

Some helpful links:

DoD Announcement

Fact Sheet

Strategies to Reduce the Potential Data Breaches by Sophisticated ATM Skimmer Technology

Victoria Daka, Regulatory Compliance Specialist

On Monday, Bernadette blogged about the Understanding Risks in Electronic Payment Systems article from the latest NCUA Report.  Today, I’d like to take a look at another article from the NCUA Report, which focuses on the sophistication of ATM skimmer technology and what credit unions should be doing to prepare for this type of attack and potential breach of member information.

Did you know that “22% of all data breaches reported in the financial services sector were credit card skimming attacks and that nearly 87% of skimming attacks were carried out on ATM’s?”  Sophisticated ATM skimming attacks are now ubiquitous because of the ease in obtaining and cheapness of skimmer technology. As such, Credit Unions should take steps necessary to reduce the potential for card skimming. Here’s a snippet from the article, with steps credit unions can take to reduce the potential of card skimming:

"Use Tamper-resistant Terminals: ATMs are increasingly designed with this in mind. Credit unions should consider replacing older machines with newer and better protected terminals.

Use Tamper-evident Controls: Automated video monitoring can detect any potential signs of tampering or damage.

Encourage Users and Members to Be Vigilant: Educate members about the potential for card skimming and encourage them to report anything out of the ordinary immediately. For example, a photo of the card readers and keypads a credit union uses could be posted on its website. This would let members know not to use the ATM if it has been altered in any way.

Inspect ATMs Frequently: Have staff inspect ATMs as often as possible to reduce the potential that a skimmer could be in place. Scratches or other signs of excess wear could be signs of tampering.

Place ATMs in Areas Hard for Criminals to Tamper with Them: This includes credit union lobbies, drive-up areas or in secured spaces where users must swipe their ATM cards to enter. In each of these areas, video monitoring could be used to capture any unusual activity.”

 The article is available in its entirety here.

NCUA Report; Understanding Risks in Electronic Payment Systems

Written by Bernadette Clair, Senior Regulatory Compliance Counsel

A couple of weeks ago, NCUA released its November 2014 Report. Featured articles include:

• Office of National Examinations and Supervision Report: ATM Skimmers: Can You Spot Them?
• Chairman’s Corner: Honoring Our Nation’s Veterans
• Board Perspectives: Taking the Time to Get it Right
• Board Actions October 2014: No Share Insurance Fund Premium for 2014; Board Approves Proposed Amendments to Corporate, Flood Insurance Rules
• Region II Report: Understanding Risks in Electronic Payment Systems
• Office of Small Credit Union Initiatives Report: Five New NCUA Videos to Fight Fraud
• Office of National Examinations and Supervision Report: Mobile Banking, Payments Increase Among Smartphone Users
• Find a Credit Union with our Locator App

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Understanding Risks in Electronic Payment Systems. One of the articles in this month’s NCUA Report that caught my attention discusses the risks associated with electronic payment systems (ACH, ATM, wire transfers, and remote deposit capture) that credit unions should consider when offering or expanding these services. These risks fall into several familiar categories – credit, fraud, compliance, liquidity, systemic, operational or transactional, strategic, and reputation.

Here’s a snippet from the article, with just a few of the questions that NCUA has developed to help credit unions develop electronic payments risk-management policies and procedures:

“Policy and Procedures — Are our policies sufficient enough to address the risks associated with our credit union’s activities? Do our policies describe program objectives, the board’s risk appetite and tolerances? Have we identified and formally approved all activities the credit union will engage in? Do our written procedures match our current practices? Do our current practices address such things as Bank Secrecy Act or customer identification and verification concerns? Have we established and documented our incident response and communication expectations? Does our credit union have effective internal controls?

Audit — Has my credit union completed an acceptable audit? Was the audit completed by a person independent of my credit union’s operations? Do our internal audits sufficiently identify potential risk across all operational areas? Has my credit union taken action to correct any issues found in the audit?

Risk Assessment — Has our management evaluated the risks associated with electronic payments processing? Is our credit union’s risk assessment commensurate with the type and complexity of our activities? Does the assessment consider all categories of risk? Does it identify inherent risk, risk mitigating controls in place and residual risk?”

For the complete list of questions NCUA has developed, as well as links to several NCUA Letters to Credit Unions containing additional guidance, the article is available in its entirety here.

The 2014 Version of the Bank Secrecy Act/Anti-Money Laundering Examination Manual

By Eliott C. Ponte, Regulatory Compliance Counsel

On Wednesday, the Federal Financial Institutions Examination Council (FFIEC) released a revised Bank Secrecy Act/Anti-Money Laundering Examination Manual (BSA/AML Manual).  Revisions were made throughout the BSA/AML Manual.  The sections with more significant revisions were noted in the BSA/AML Manual table of contents with “2014” in the subsection’s title.  In addition, the revised BSA/AML Manual has two new sections:  Prepaid Access, which replaces E-Cash; and, BSA E-Filing System. 

Significant updates include:

“Suspicious Activity Reporting (SAR) – Incorporated new SAR E-Filing requirements; guidance on the extension of SAR filing for continuing activity; clarification of prohibitions on disclosing a SAR; and guidance on sharing SARs with affiliates.

Currency Transaction Reporting (CTR) – Revised to incorporate new CTR E-Filing requirements and new guidance issued by FinCEN since 2010 related to currency transaction aggregation for businesses and exemptions.

Foreign Correspondent Account Recordkeeping – Included regulations relating to the Comprehensive Iran Sanctions, Accountability, and Divestment Act.

Foreign Bank and Financial Accounts (FBAR) – Incorporated new FBAR filing requirements.

International Transportation of Currency or Monetary Instruments Reporting (CMIR) – Clarified monitoring and reporting obligations under the BSA for international transportation of currency or monetary instruments.

Correspondent Accounts (Foreign) – Included additional guidance in the section on risk mitigation.

Bulk Shipments of Currency – Revised to incorporate FinCEN’s CMIR guidance for common carriers of currency, including armored car services (August 1, 2014), and clarify monitoring and reporting obligations under the BSA.

Automated Clearing House Transactions (ACH) – Incorporated National Automated Clearing House Association (NACHA)-The Electronic Payments Association modifications related to international ACH transactions and further defined third-party service providers.

Prepaid Access – Replaced Electronic Cash section and included an expanded discussion of risk factors and risk mitigation related to prepaid access.

Third-Party Payment Processors – Updated to reflect interagency guidance issued since 2010.

Embassy, Foreign Consulate, and Foreign Mission Accounts – Updated to incorporate the interagency guidance on accepting accounts from foreign embassies, consulates, and missions.

Nonbank Financial Institutions – Incorporated new FinCEN regulations for Money Services Businesses (MSBs) related to certain foreign-located persons engaging in MSB activities; new regulations related to prepaid access programs; and guidance regarding virtual currency administrators and exchangers.

Appendix T: BSA E-Filing System – Created to provide examiners with information on the FinCEN BSA E-Filing System.” 

Interagency Statement (Dec. 2, 2014).

The 2014 version of the BSA/AML Manual is available on FFIEC’s website in PDF format.  The non-PDF version of the Manual has not been published to FFIEC’s website as of the date of this blog post.  FFIEC has not stated it plans to remove the online version of the BSA/AML Manual from its website, thus NAFCU expects FFIEC’s website to be updated shortly. 

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 Programming Note: NAFCU's offices will close at 1:30 today for our annual holiday party.  We will be back to our desks on Monday. Have a great weekend!

CFPB Provides Guidance on Using Social Security Disability Income in Mortgage Lending

Written by Angela Meyster, Senior Regulatory Affairs Counsel

Two weeks ago, the CFPB released a bulletin providing guidance for lenders using consumers’ Social Security disability insurance and Supplemental Security Income (collectively, Social Security disability income) to determine whether to provide mortgage loans.  The guidance stems from the recurring issue that many consumers relying on Social Security disability income cannot provide proof of how long they will continue to receive their benefits and lenders are worried that, without this proof, they cannot adequately determine a consumer’s ability to repay. Generally the Social Security Administration (SSA) will provide proof that a consumer is currently receiving benefits, but will not forecast for how long the consumer will continue to receive the benefits.

The Bureau in its bulletin cites critically to instances where, in an effort to address this issue, applicants have been asked by mortgage lenders for information about their disability or a statement from their physician about the duration of their disability.

According to the Bureau, to verify income under the CFPB’s Qualified Mortgage debt-to-income ratios, a lender must look at whether the SSA benefit verification letter or equivalent document includes a defined expiration date for payments.  If there is no explicit mention that benefits will expire within three years of loan origination, the lender can treat the benefits, for purposes of being compliant with the Qualified Mortgage rule, as likely to continue. 

The CFPB’s bulletin also highlights that if a lender places “unnecessary documentation requirements” (such as those mentioned above) on a consumer who is receiving Social Security disability income, the CFPB may subject the lender to a fair lending violation. Specifically, fair lending concerns may arise under the Equal Credit Opportunity Act (ECOA) and Regulation B. Under the ECOA and Regulation B, creditors cannot discriminate against an applicant on the basis that the applicant’s income derives from a public assistance program.  A creditor may only take into account the length of time an applicant will remain eligible to receive income from such a program. Creditors should also avoid creating a disparate impact by imposing a different set of requirements for applicants deriving income from public assistance programs. The CFPB encourages creditors to spell out clearly their verification requirements for Social Security disability income, train their personnel in fair lending practices, and ensure strict compliance with underwriting policies.

Finally, the Bulletin outlines a similar approach the Department of Housing and Urban Development, Department of Veterans Affairs, Fannie Mae, and Freddie Mac have taken with respect to Social Security Disability Income.

For more information about compliance with the fair lending requirements of ECOA and Regulation B, see CFPB Bulletin 2012-04: Lending Discrimination.

CFPB’s Latest Rulemaking Agenda; One-Stop-Shop NAFCU Compliance Resource You Won’t Want to Miss

Written by JiJi Bahhur, Director of Regulatory Compliance

Recently, the CFPB posted a semi-annual update of its rulemaking agenda which explains and details the work it has done in 2014 and outlines the areas it intends to focus on in 2015.  If you have not seen the rulemaking agenda before, it includes items that the CFPB is/has been focusing on and states what stage in the rulemaking process that particular item is in: pre-rule, proposed rule, or final rule. 

I won’t go into any detail, but if you’re interested in seeing what the CFPB has been up to, take a look at the semi-annual update and the rulemaking agenda – both are short and sweet and easy to read.  But now for a shameless plug: Are you looking for a one-stop shop year-end review of the NCUA’s and CFPB’s activities from this year?  If so, you’re in luck!  NAFCU’s Compliance team has made available just that – an article that synthesizes the final rules, proposals, and other guidance provided by the NCUA and CFPB during 2014 and also what to expect in the near future.  If you are a NAFCU member, you can access this compliance resource in NAFCU’s December Compliance Monitor issue (NAFCU log-in required).  For a direct link to the article, click here (NAFCU log-in also required).     

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Speaking of NAFCU's December Compliance Monitor, members will also find an article outlining the CFPB's Annual Privacy Notice rule.