NAFCU Compliance Blog

CFPB Bulletin on Non-Discriminatory Access to Credit for Mortgage Applicants Who Receive Public Housing Assistance; Updated Mortgage Origination Examination Procedures; Public Inquiry into Student Loan Servicing Practices

Written by Bernadette Clair, Senior Regulatory Compliance Counsel

CFPB Bulletin on Non-Discriminatory Access to Credit for Mortgage Applicants Who Receive Public Housing Assistance. The CFPB recently released Bulletin 2015-02, Section 8 Housing Choice Voucher Homeownership Program. The bulletin is intended to remind creditors “of their obligations under the Equal Credit Opportunity Act (ECOA)¹ and its implementing regulation, Regulation B,² to provide non-discriminatory access to credit for mortgage applicants using income from the Section 8 Housing Choice Voucher (HCV) Homeownership Program.³” (Footnotes omitted). The Section 8 Housing Choice Voucher Homeownership Program (Program), created to assist low-income, first-time homebuyers in purchasing homes, is funded by the Department of Housing and Urban Development and administered by participating local public housing authorities.

The Bulletin was issued in response to certain lending practices that have come to the attention of the CFPB – namely that some financial institutions have been excluding or refusing to consider income from the Program during the loan application and underwriting process, or only permitting Program vouchers to be used for certain mortgage loan products or delivery channels. The Bulletin reminds institutions of their fair lending obligations under ECOA and Regulation B regarding the treatment of income derived from any public assistance program. From the Bulletin:

“ECOA and Regulation B prohibit creditors from discriminating in any aspect of a credit transaction against an applicant “because all or part of the applicant’s income derives from any public assistance program.”⁶ “Any Federal, state, or local governmental assistance program that provides a continuing, periodic income supplement, whether premised on entitlement or need, is ‘public assistance’ for purposes of the regulation. The term includes (but is not limited to) . . . mortgage supplement or assistance programs . . . .”⁷ As such, mortgage assistance provided under the Section 8 HCV Homeownership Program is income derived from a public assistance program under ECOA and Regulation B.

Regulation B further provides that “[i]n a judgmental system of evaluating creditworthiness, a creditor may consider . . . whether an applicant’s income derives from any public assistance program only for the purpose of determining a pertinent element of creditworthiness.”⁸ However, “[i]n considering the separate components of an applicant's income, the creditor may not automatically discount or exclude from consideration any protected income. Any discounting or exclusion must be based on the applicant's actual circumstances.”⁹” (Footnotes omitted).

The Bulletin goes on to provide guidance on managing fair lending risk in this area, such as making sure underwriting policies are clearly articulated; training underwriters, mortgage loan originators and others involved in mortgage loan origination; and monitoring for compliance with underwriting policies. For complete details, the CFPB’s press release is available here and the Bulletin is available here.

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Updated Mortgage Origination Examination Procedures. Earlier this month, the CFPB also released updated mortgage origination examination procedures, which include guidance on how the agency will conduct examinations for compliance with the TILA-RESPA Integrated Disclosure Rule (TILA-RESPA). This document can be a handy tool for those working to implement TILA-RESPA requirements in advance of the August 1, 2015, effective date. For a complete run-down of NAFCU resources to assist those working to implement the rule, check out this blog by my colleague JiJi.

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Public Inquiry into Student Loan Servicing Practices. The CFPB has issued a request for information seeking comments from the public about industry student loan servicing practices; practices related to loan repayment, including practices related to student loan repayment for borrowers in distress; the applicability of consumer protections from other consumer financial product markets (such as consumer mortgages and credit cards) to student loan servicing; and input about the availability of data on student loan performance and on borrower characteristics during repayment. Comments are due to the CFPB on or before July 13, 2015.

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NAFCU Webcast: UCC Provisions Affecting Your Credit Union. The Uniform Commercial Code (UCC) impacts many of your credit union’s lending and payment processing activities—but the connection usually isn’t obvious until there’s a problem. Avoid this issue by being well-informed. Attend this detailed webcast to learn how various sections of the UCC affects the different operations of your credit union, from lending to dishonored checks. The webcast will be held on Thursday, May 21, from 2:00 p.m. – 3:30 p.m. ET. Register here.

NCUA’s Supervisory Focus for 2014; NCUA Webinar on Exam Modernization

Written by Bernadette Clair, Senior Regulatory Compliance Counsel

NCUA’s Supervisory Focus for 2014.  Last Friday, NCUA released Letter 14-CU-02, detailing its 2014 examination focus. For 2014, the emphasis is heavy on risk mitigation. From the letter – “In 2014, NCUA will be working to ensure that credit unions identify and mitigate forward-looking risks before they threaten the viability of credit unions and the stability of the Share Insurance Fund.” (My emphasis.)

Specific areas of supervisory focus for 2014 include:

• Interest Rate Risk
• Cybersecurity Threats
• Money Services Businesses (MSBs)
• Private Student Lending

In addition to these specific areas of focus, the letter highlights compliance with new rules.  NCUA also says it will be looking to reallocate resources “more efficiently and effectively” and describes several steps NCUA will be taking in 2014, intended to improve and streamline the exam process – let’s hope so!

The information in this letter is invaluable for exam preparation this year, so be sure to give it a read, available here.

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NCUA Webinar on Exam Modernization. This month, NCUA will be hosting a free webinar on its new examination report process. The webinar will provide an overview of the changes NCUA has made to streamline and improve the consistency of the examination report process, and give participants an opportunity to get a better understanding of the new procedures related to Documents of Resolution and the examination report.

This free webinar will be held on Wednesday, January 22, 2014, at 2 p.m. EST. Register here.

Participants may submit questions in advance at [email protected]. The subject line of the email should read “Examination Modernization Webinar.”

CFPB Procedural Rule for Supervision of Nonbanks that Pose Risks to Consumers

Written by Michael Coleman, Regulatory Compliance Counsel

On June 26^th, 2013, the Consumer Financial Protection Bureau (CFPB) issued a final rule establishing the procedures which the CFPB will use to bring under its supervisory authority certain nonbanks whose activities it has reasonable cause to determine pose risks to consumers. The effective date of the rule is August 2, 2013.

Here is an excerpt from the CFPB’s press release summarizing the nature of the final rule:

“This rule outlines procedures to notify a nonbank that it is being considered for supervision because the CFPB may have reasonable cause to determine that it poses a risk to consumers. The rule also sets out the procedures that the CFPB will follow to give the nonbank in question a reasonable opportunity to respond to such notice. For example, the rule dictates what the CFPB requires in both the notice and the response. And, the rule creates a mechanism for nonbanks to file a petition to terminate the CFPB’s supervisory authority after two years.”

Once effective the procedures will be located in The CFPB’s Regulations 12 C.F.R. Part 1091.

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Keep in mind that there are other Dodd-Frank provisions which give the CFPB supervisory authority over nonbank institutions, here is another excerpt from the press release on the procedural rule:

“In addition to the authority to bring nonbanks under the CFPB’s supervisory authority based on risk determinations, the Bureau also has authority under the Dodd-Frank Act to supervise nonbanks, regardless of size, in certain specific markets: mortgage companies (originators, brokers, and servicers including loan modification or foreclosure relief services); payday lenders; and private education lenders. The CFPB can also supervise the “larger participants” in other nonbank markets as the Bureau defines by rule. The Bureau has issued two rules defining larger participants: one rule for the consumer reporting market that went into effect in September 2012, and the other for the debt collection market that went into effect in January 2013. A proposed larger-participant rule for the student loan servicing market was issued in March 2013.”  (Emphasis added.)

As the press release notes, the CFPB has taken several actions related to its supervisory authority over nonbanks. Below are some links to the final and proposed rules:

• Final rule defining “larger participants” for the consumer reporting market
• Final rule defining “larger participants” for the debt collection market, and technical corrections to the final rule.
• Proposed rule defining “larger participants” for the student loan servicing market

We can expect that the CFPB will remain active in this area, keep your eyes peeled for future developments. 

Today's Reports are Tomorrow's Regulations - Private Student Loans Edition

Written by PJ Hoffman, Regulatory Affairs Counsel

In case you haven’t noticed, it seems that everyone has an opinion about private student lending. In just the past few months we have seen regulators, legislators, and news outlets all getting in on the act. If your credit union is involved with private student lending or anticipates entering into the market sometime soon, then you need to be paying attention. After all, today’s reports are tomorrow’s regulations. 

We’ve been ringing the bell here at NAFCU on student lending as reports and requests for information have come up, but it is important to understand the landscape going forward.

The CFPB has had this issue in their sights for a while now. In October 2012, the CFPB’s Student Loan Ombudsman released a report on private student loans that highlighted and summarized information and complaints received by the CFPB concerning the student loan marketplace. Many of the issues centered on frustration about the inability to speak with personnel empowered to negotiate a repayment plan, inability to refinance, and inability to access repayment plans previously advertised. While the CFPB acknowledged that credit unions and other small financial institutions generated very few complaints and that increased participation from those same small institutions might benefit the market, it is incumbent upon us to see that today’s reports are tomorrow’s regulations.

The CFPB has taken it two steps further in focusing on financial products offered to students, which Steve mentioned here on this blog, when they introduced two requests for information on financial products marketed to students through colleges and universities and another on the private student loan market. NAFCU has put out Regulatory Alerts on both available here with comment letters to follow.

Just last week, the CFPB offered a proposed rule to define larger participants of the student loan servicing market. This would extend the CFPB’s supervisory authority to encompass any non-bank and non-credit union that services over 1 million student loans. Although this rule will not affect credit unions directly, it will undoubtedly change the student loan servicing market and therefore any credit union that deals in that market.

The CFPB is not the only regulatory agency keep their eye on private student lending. Our own NCUA just published an article in their March report titled “Understanding The Risks of Private Student Loans” where they warn of upcoming risks to credit unions regarding private student loans. With quotes like “NCUA anticipates private student loan delinquency rates will likely increase in coming years” and “NCUA expects credit unions to establish reasonable concentration limits for a private student loan portfolio to protect against risk” you know that the NCUA is keeping a keen eye on private student lending. It’s not a coincidence that this article is coming out around the same time as the CFPB requests and we need to be sure to read the tea leaves going forward on this issue.

We’ll be keeping you informed as we hear and see new developments but if your credit union is involved with private student lending please be aware of the recent increase in attention by regulators. 

CFPB Focusing on Students (and Private Student Loans); Free UDAP Webinar

Written by Steve Van Beek

The CFPB recently reiterated their focus on financial products offered to students.  A brief discussion of two current efforts is below. 

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CFPB Inquiry into Campus Products.  In late January, the CFPB launched an inquiry into the financial products marketed to students through colleges and universities.  If your credit union has a relationship with a local college or university (or if you CU is sponsored by one!), be sure to keep an eye on this issue.   

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CFPB Focusing on Private Student Loans.  The CFPB has not been shy when indicating they will be focusing heavily on private student loans.  If your credit union makes private student loans, be sure to track the CFPB’s actions and ensure you are ready for future changes.  On February 21, the CFPB penned two blog posts on student loans.  The first looked at student debt and schools.  The second was titled “Help Stop the Student Debt Domino Effect.”  The CFPB also announced a new Notice and Request for Information on the student loan market.  NAFCU’s Regulatory Affairs team will be providing a Regulatory Alert on this request for information and will also be drafting a comment letter to the CFPB. 

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Free UDAP Webinar.  On March 5, The Philadelphia Federal Reserve’s Consumer Compliance Outlook will feature a free webinar on UDAP - Analysis, Examinations, Case Studies, and Emerging Risks.  The webinar will look at:

• Consumer Financial Protection Bureau (CFPB) UDAAP and Federal Reserve Bank UDAP legal authorities

• UDAP legal analysis and examination procedures

• UDAP and bank holding company risk

• Case studies and emerging areas of risk

• Recommendations for implementing an effective UDAP compliance program

The webinar will start at 2:00 p.m. EST on March 5th.  With the CFPB’s future actions in this area unknown, be sure to tune in.

Mortgage Headache Areas; Upcoming Mortgage Reform Webcasts

Written by Steve Van Beek

Yesterday was NAFCU's first webcast as part of our Mortgage Reform Webcast Series.  I provided an overview of the seven new mortgage regulations - focusing specifically on the scope & applicability of the new requirements.  

I also provided some insight on "Headache Areas" and included this list at the end of the presentation:

• Determining Exemption Applicability

• New Notices – Content-Rich and Strict Timelines

• Error Resolution & Information Request Procedures

• Loan Originator Compensation Determinations

• Implementing So Many Changes At One Time

And, there will be many additional headaches as credit unions work toward implementing the new requirements.  Even self-induced ones.  

There is some hope on the horizon as the CFPB issued their best press release of their history which highlights their Implementation Plan for New Mortgage Rules.  The CFPB's plan indicates they are listening to NAFCU and credit union concerns regarding the overwhelming burden of reading, understanding, interpreting and implementing numerous requirements simultaneously.  Of course, we'll have more information on the CFPB's plan in future blog posts.

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Upcoming Mortgage Reform Webcasts.  As I mentioned, yesterday's webcast was the first of our series and registration for the next three is now open.

• CFPB's Ability to Repay and Qualified Mortgage Requirements - March 6, 2013 - 2:00 p.m. to 3:30 p.m.

On March 6, Andy Keeney from Kaufman & Canoles will be examining the details of the CFPB's Ability-to-Repay Requirements and Qualified Mortgage Standards.  Andy will walk through the new underwriting guidelines - including the debt-to-income requirements - and explain how these rules will impact credit union mortgage lending.  And, importantly, the steps your credit union needs to take to comply by January 10, 2014.  

• Digging Deeper: CFPB's Mortgage Rules - March 27, 2013 - 2:00 p.m. to 3:30 p.m.

I'll be joined by my colleagues JiJi Bahhur, Bernadette Clair and Mike Coleman as we explore details of the CFPB's new mortgage requirements.  We'll provide answers to Frequently-Asked-Questions that our team has fielded from NAFCU member credit unions.  And, we'll take a look ahead at what other areas the CFPB is likely to address in 2013.  

• Which New Requirements Apply to HELOCs? - April 10, 2013 - 2:00 p.m. to 3:30 p.m.

I'll provide a detailed look at which requirements apply to home equity lines of credit and - just as importantly - which do not apply so that your credit union can best position your implementation strategy.  If your credit union makes HELOCs, this is one you'll want to attend as the new requirements are sprinkled throughout the CFPB's 3507 pages!

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Programming Note:  NAFCU's offices will be closing early tomorrow and will be closed on Monday for the Federal holiday.  We'll have a blog post tomorrow and then start back up again on Tuesday.   

CFPB Sharing Complaint Data; Unverified Complaints; Feedback on NCUA Process

Written by Steve Van Beek

Back in mid-December, the CFPB announced it would be sharing consumer complaint data with state regulatory agencies.  They also note that this is just the beginning:

"In the future, we’re planning on building ways to accept complaints and information from the agencies as well, and to make the data available to other federal agencies, state attorneys general, local agencies, congressional offices as appropriate, and other governmental organizations like the California Monitor (a program of the California Attorney General) and the Office of Mortgage Settlement Oversight."

The announcement then goes on to provide a summary of the CFPB's complaint process:

"What happens when I file a complaint?

When a consumer files a complaint, we screen it to make sure that it’s complete and not a duplicate of another complaint we’re already working on for that consumer. Next, we send it to the company in question and ask them to reply to the complaint within 15 days and expect them to close all but the most complicated complaints within 60 days. After the company responds, we publish a selection of the data (with information identifying the consumer removed) in our public Complaint Database."

You'll easily notice that there is no verification process.  And, the Complaint Database's disclaimer doesn't exactly jump off the page.  Of course, this is an issue we've discussed over and over on the blog - so much so that we have a Member Complaints category.  

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Initially, it is important to remember that credit unions under $10 billion are not included in the Consumer Complaint Database.  The CFPB will forward any complaints from these credit unions to NCUA and credit unions will need to follow NCUA's procedures for responding to member complaints (more on this at the end of the blog post).  

Unverified Complaints.  So, what is the big deal with unverified complaints?  The reputation risk issue is one that cannot be ignored.  In this age of viral media - where a simple complaint or issue can fly through blogs, Facebook, Twitter - it is much harder to correct inaccurate information.  Sometimes, once the story is out there, it is....well, out there.  

But, there is another angle that could be even more dangerous.  The CFPB's Annual Report on Student Loans and the companion report - The Next Front? Student Loan Servicing and the Cost to Our Men and Women in Uniform - both use consumer complaints as a focal point to help show the current regulations or enforcement is insufficient.  

The latter quotes directly from consumer complaints, for example:

        
That comes from page 5 of the Report.  An earlier quote includes this footnote:  "This report cites information from specific complaints submitted to the CFPB. In these cases, the consumers have provided consent to include the details of their complaints."

Again, there is no mention of verification of the complaints.  I'm interested, was the rate incorrect?  We don't know.  But, the CFPB is implying it was by including one side of the story.  Remember:  The institution - whichever institution this was from - is prohibited by privacy laws from providing any information about the member's account.  So, we have the one side of the story.

Of course, I'm not saying these complaints are not true.  I'm just saying they are unverified (if they were verified, the CFPB should include that information).  

And, I'm not saying that institutions always do everything correctly.  For example, if this complaint is accurate - the institution has a lot of work to do:

"According to a complaint received by the CFPB, one borrower had six loans with a servicer, two of which had interest rates above six percent and four of which had interest rates below six percent. Instead of reducing the interest rate on the two higher-rate loans to six percent and leaving the four lower-rate loans untouched, the servicer simultaneously increased the interest rate on the lower-rate loans up to six percent."

Or, it could have been a mistake that was quickly corrected by the institution.  We just don't know.

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The New Cycle?  The reason I bring this up is that this seems to be the start of a new type of regulating that credit unions need to be aware of.  Or, at the least it is a new type of justifying the need for new regulation.  

Think about it.  The CFPB is soliciting consumer complaints (remember the flashing red "complaint button" on their first website?)  Then, they write a report (usually to Congress) using the complaints to argue there are issues that need to be corrected.  There might also be testimony to explain the report and what they've found.  After that?  Well, it might just be that the reports help build the case for a new regulation (or a new law from Congress).  All with unverified consumer complaints.  

At this point, we don't know.  But, the CFPB seems to be falling short of their data-driven analysis goal:

"The CFPB is a data-driven agency. We take in data, manage it, store it, share it appropriately, and protect it from unauthorized access. Our aim is to use data purposefully, to analyze and distill data to enable informed decision-making in all internal and external functions."

And, remember - the new requirements that come from these new regulations or laws will not be limited to credit unions with more than $10 billion in assets.  The new requirements will apply to everyone.  

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NCUA Complaint Process.  Taking a little different angle here.  We've detailed the NCUA Complaint process a couple of times on the blog.  Most recently here and here.  What we are interested in from blog readers is if there are areas NCUA could improve?  If so, please let us know.  We'll be sure to raise the issues with NCUA and see if some of the issues can be smoothed out.  

CFPB Updates Thresholds; Waiting on HMDA

Written by Steve Van Beek

Recently, the CFPB announced the 2013 threshold levels for HOEPA/Section 32/High-Cost loans as well as exemption levels for both Reg Z and Reg M.  They haven't released the HMDA asset threshold for 2013 yet, but we'll be sure to pass that along when it is published (last year's release was, unfortunately, delayed until February 15th).  

• The HOEPA fee threshold for 2013 will be $625 in fees.  

• The Regulation M (consumer leasing) threshold for 2013 will be $53,000 (up from $51,800 in 2012).

• The Regulation Z threshold for 2013 will also be $53,000 (up from $51,800 in 2012).  

For the Reg Z threshold, a couple of things to keep in mind:

• Private student loans are subject to Reg Z regardless of the loan amount.
• Loans secured by real property (mortgages) are subject to Reg Z regardless of the loan amount.  
• Loans secured by personal property used or expected to be used as the member's principal dwelling are subject to Reg Z regardless of the loan amount.

Additionally, most credit unions provide the Reg Z disclosures for all loans (even a $55,000 closed-end car loan) in order to keep consistent for their loan teams.  

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HMDA.  Last year's asset threshold was released on February 15th even though the Federal Reserve had historically announced the updated threshold in December of the year prior.  Hopefully the CFPB has learned from its growing pains of the first year and realizes how important it is to be timely with issues as important as the annual HMDA asset threshold.

CFPB Report on Private Student Loans

Written by Michael Coleman, Regulatory Compliance Counsel

On Monday we blogged about a report on private student loans released by the CFPB's Student Loan Ombudsman. Today we would like to take a closer look at some of the details of the report. The report indicates that the current outstanding student loan debt is now over $1 trillion, with private student loans accounting for more than $150 billion (15% of the debt).  Furthermore, there are at least $8 billion of private student loans in default, representing more than 850,000 individual loans.  Student loans have now surpassed credit cards as the largest source of unsecured consumer debt. 

The report highlights and summarizes the information and complaints received by the CFPB concerning the student loan marketplace. The CFPB received approximately 2,900 complaints and other submissions from consumers concerning private student loans, the vast majority of which (95%) were about loan servicing. The report summarized some of the issues borrowers identified in their complaints:

"Inability to speak with personnel empowered to negotiate a repayment plan.  By far, the most common concern communicated by borrowers has been the difficulty negotiating a repayment plan with their servicer in periods of unemployment, underemployment, or financial hardship.  Many borrowers report frustration that they are unable to identify appropriate personnel that can make a determination about their repayment options.

Inability to refinance. Many student loan borrowers have a limited credit history when applying for a private student loan— and their interest rate reflects a high level of risk.  But as borrowers build a credit profile, graduate, and earn income, they are often unable to refinance existing student debt at a lower rate— in stark contrast to the market for mortgage refinance products. We have heard from borrowers who say they are looking for loans with more attractive terms, but many have been unable to take advantage of today’s historically low rates. 

[…]

Inability to access repayment plans previously advertised.  Many private student loan borrowers are able to enroll in alternative repayment arrangements included in the terms and conditions of their loans.  However, some borrowers note that enrolling in a new repayment arrangement is a difficult process.  Some servicing personnel may not be fully aware of all policies or incentive plans available to private student loan borrowers. "

The report also featured a discussion from the CFPB Student Loan Ombudsman on the issues identified in the complaints. One point raised was that the complaints received concerning student loan servicing bore a striking similarity to the complaints received concerning mortgage loan servicing. Another focused on the difficulty that borrowers face in modifying or refinancing student loans, and that the CFPB would welcome "creative efforts by lenders to help borrowers restructure their debt prior to or after default."

In the discussion the CFPB Student Loan Ombudsman had this to say about credit unions' participation in the private student loan market: 

"Community Banks and Credit Unions

A number of leaders from small financial institutions have expressed interest in developing longterm relationships with young customers but note that many of them are unable to enter the mortgage market due to their student loans.  One way that small financial institutions might assist younger customers to get closer to homeownership is to offer products that allow them to refinance any student loans they might have with rates in excess of their perceived repayment risk.  Small financial institutions might even be able to assist customers worried about falling behind on student loans by offering products that might allow them to be successful.  

The CFPB received very few complaints from borrowers with private student loans from small financial institutions.  Increased participation by small financial institutions might benefit the market." (emphasis added)

The report notes that 87% of the complaints were directed at just 7 companies (take a look at Table 2 on page 5 of the report), which is not surprising considering the concentration of the market. However, as the report indicates, the CFPB received very few complaints from borrowers with private student loans at credit unions, and that increased participation by credit unions in the private student loan market might be beneficial. 

The CFPB also released a fact sheet and press release regarding the report. 

CFPB Report on Private Student Loans; CFPB Remittances Webinar; NAFCU's Offices Closed

Written by Steve Van Beek

We'll keep this blog post brief as we’ll have additional information on the CFPB reports in future blog posts.

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Private Student Loan Report.  On October 16th, the CFPB issued a report on private student loans.  Here is from the press release:

"Today’s report, which was mandated by Congress, analyzed approximately 2,900 private student loan complaints, comments, and other submissions and input from borrowers. The report found that roughly 95 percent of the complaints are about loan servicing – when borrowers try to pay back their debt or are unable to pay."

The report is available here.  A fact sheet is available here.   

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Student Loans and Servicemembers.  On October 18th, the CFPB issued a report on student loans and servicemembers.  Prominent in the report were discusses of student loans and the SCRA:

"Many servicemembers navigate hurdles that may be unnecessary in order to receive the SCRA interest rate cap. Once a borrower has qualified for this interest-rate cap, the SCRA requires the servicer to continue to provide this benefit for the duration of the servicemember’s time on active duty, as reflected in the servicemember’s orders. We have received complaints from servicemembers, on active duty for multiple years, who reported that they were told that their interest-rate cap would expire annually, and were subsequently required to submit  additional orders in order to retain this benefit."

The report is available here.  The CFPB also released a Guide for Servicemembers with Student Loans.  

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CFPB Remittances Webinar.  If you missed the CFPB's webinar on remittances, you can view the archive here (slides are here).  The Small Entity Compliance Guide is also available.

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NAFCU Closed.  NAFCU follows the Federal Government Operating Status and our offices will be closed today due to Hurricane Sandy.  NAFCU Members:  If you have compliance questions, please email us at [email protected].  If you call, please leave a voicemail and we'll get back to you as soon as we can.   

For those in and around the Hurricane area, be safe!

Know Before You Owe - Student Loans; Welcome Mike Coleman

Written by Steve Van Beek

The CFPB announced new initiatives in their Know Before You Owe campaign for student loans.  The CFPB released quite a few different documents and announcements including:

• Blog Post on Paying for College: Help us make it easier for you to choose
• Press Release announcing their new webpage and the Financial Aid Comparison Shopper

This is in addition to the CFPB's other efforts on Know Before You Owe for student loans, a separate shopping sheet example, debt repayment assistance and student loan complaint process.

While the CFPB's Know Before You Owe on student loans won't directly impact credit unions - it is clear that the CFPB has its sights set squarely on the student loan market - especially private student loans - and credit unions will want to follow the CFPB's moves in this area.  

Here are Director Cordray's remarks at the announcement.   

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Welcome Mike.  Those of you have emailed or called NAFCU Compliance recently may have talked with our newest Regulatory Compliance Counsel - Mike Coleman.  Mike joined us in mid-February and attended NAFCU's Regulatory Compliance School last month.  Mike also successfully passed all four NAFCU Certified Compliance Officer (NCCO) exams and is now an NCCO (I guess it didn't hurt to have one of his first assignments to read the NAFCU GPS and check every single electronic link).    

NAFCU Members:  We've updated our Contacting NAFCU's Compliance Team document.  Be sure to download the contact sheet and pass along to your colleagues.  For more information on NAFCU's Compliance resources, click here.

Non-Members:  We have a six-month trial membership program that your credit union might qualify for.  Additionally, all NAFCU conferences (including Regulatory Compliance Seminar) and webcasts are open to anyone regardless of NAFCU membership.