Written by Elizabeth M. Young LaBerge, Regulatory Compliance Counsel
I hope everyone had a wonderful Thanksgiving. Last week felt like a short one to me, but it appears that NCUA and the CFPB managed to cram in a full weeks’ worth of regulatory news. Here’s a quick catch-up:
NCUA Panel Discussion on Reaching Hispanic Members
Yesterday afternoon, NCUA held a panel discussion, “Unique Challenges and Opportunities Servicing Hispanic Credit Union Members,” which emphasized the opportunities for credit unions that currently exist within the Hispanic population, and, importantly, practical, useful guidance and suggestions on what credit unions can do to engage potential Hispanic members.
The panel discussed common pitfalls in engaging potential Hispanic members, including the use of CIP policies or procedures which do not accommodate the documentation which can be provided by new immigrants. The panelists, including Sergio Osuna, a Supervisory Examiner for NCUA’s Region V Office, specifically referenced the matrícular consular, an identification card issued by a Mexican consulate, in place of U.S. government issued identification. The panel recommended that credit unions that wish to engage first-generation Hispanic immigrants, approximately half of which are either unbanked or underbanked, speak with the consulates of the relevant populations in their community to determine appropriate foreign government-issued identification.
The panelists also discussed underwriting loans for members who do not have social security numbers, marketing and engagement strategies, products to which Hispanic members respond, best practices for serving Hispanic members and field of membership considerations for adding Hispanic communities to a credit union’s charter. Any credit union which is considering outreach to Hispanic members of its community should consider giving the panel discussion a watch. It will be available via NCUA’s website in 4-5 weeks.
Post-Turkey Day Regulator Round-Up
CFPB Monthly Complaint Snapshot
On November 24, 2015, the CFPB released its monthly consumer complaint snapshot report. The November complaint report highlighted bank account and service complaints. It reported an increase in CFPB complaints pertaining to prepaid products ― though debt collection, credit reporting and mortgage complaints continued to be the most-complaint-about issues. The regional focus of the November report was on Connecticut and the Hartford metro area.
Adjustment of Dollar Thresholds in Regulations Z and M
On November 25, 2015, the CFPB announced that the thresholds for transaction exemptions under regulations Z and M will not be adjusted from the 2015 level of $54,600. The notice submitted to the Federal Register for Regulation Z is here, and the notice for Regulation M is here.
Adjustment of Threshold for Exemption from Appraisal Requirements
Also on November 25, 2015, the CFPB announced that the threshold amount for loans exempt loans from special appraisal requirements for higher-priced mortgage loans under 12 C.F.R. § 1026.35(c)(2)(ii) will also remain the same as it did for 2015: $25,500. The notice submitted to the Federal Register is here.
NCUA Debuts New Share Insurance Videos
On November 30, 2015, NCUA announced the release of three new videos directed at consumers to help them understand their insurance coverage on their deposits. The videos include a Share Insurance Coverage Overview, How to Use NCUA’s Share Insurance Estimator and Account Ownership Types.
A Christmas Surprise: What Dog Is This?
I have mentioned my dogs, Boomer and Ollie, in previous blog posts. Ollie is former stud dog rescued from a Pennsylvania puppy mill. Originally, the rescue organization advised us he was a one-year old bichon frise. When we arrived in Shamokin, Pennsylvania, we realized pretty quickly that was not the case. To date, every vet we’ve been to has had a different guess. We have finally buckled down and ordered a genetic test to determine his breed. Is little Ollie just a Maltese with a bad haircut? Or is he a Coton De Tulear, the royal dog of Madagascar? Only time and genetic testing will tell. Let me know if anyone has a guess ― the results should arrive around Christmas. Claiming to be right after the fact does not count!
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