NCUA Letter 16-CU-03 Annual Privacy Notice Requirement

The NCUA issued Letter 16-CU-03 clarifying their position on the annual privacy notice requirement as a result of the changes to the Gramm-Leach-Bliley Act (GLBA).  We previously blogged about the requirements at The Letter states: Based on the amendment, your credit union need not provide an annual privacy notice if: Your policies and practices have not changed since your … Read More

DCU 2016 Exam Focus

The Division of Credit Unions has published Bulletin B-16-02, which establishes their exam focus for 2016. The bulletin lists four focus areas for 2016: Cybersecurity This goes hand-in-hand with NCUA’s focus of cybersecurity risks. The DCU hired Security Compliance Associates (SCA) to assist them in performing IT security examinations. The main differences that credit unions will see in the Division’s … Read More

Military Lending Act Covered Borrower Database Access

If the credit union wishes to use the DMDC (Defense Manpower Data Center) direct connection capability (under development) to identify borrowers covered under the MLA (Military Lending Act) should email a request to the DMDC at, by February 1. The MLA places certain protections over covered borrowers, including a cap on annual percentage rates, so credit unions need to … Read More

Same-day ACH Rule FAQs

The Federal Reserve published a list of frequently asked questions regarding the same day ACH transactions effective September 2016. The questions cover the three-implementation phases, operator processing schedule, same day entry fee and accounting, and limits, among other topics. More information about the same day ACH rule is available at

CUSO Registration

NCUA’s CUSO Registry will be available for CUSOs to begin registering on February 1, 2016.  CUSOs must register between February 1 and March 31. Federally insured credit unions are required to enter into written agreements with any CUSOs they make loans to or invest in. Each agreement must be signed before a credit union invests in or lends to a … Read More

FI counsel to discuss “alternative” offers re: Home Depot/Visa settlements

Reprinted from 01/15/2016 ATLANTA (1/15/16)–A conference call is set for Wednesday for financial institution plaintiffs–which includes credit unions–regarding settlement offers from Visa regarding the Home Depot data breach lawsuit. Counsel for the financial institutions who brought the class action are hosting the call, which is set for 2 p.m. (ET). The call will discuss alternative recovery offers (AROs) that Visa … Read More

New Savings Bond Guide

The Treasury has issued an updated version of The Guide to Cashing Savings Bonds. The Guide in provided in an interactive PDF format and covers authenticity and eligibility, customer entitlement, identify verification, required identification documents and payment. The Guide replaces all past versions of this document.

HMDA Data Collection Requirements for 2016

NCUA Letter 16-RA-01 The NCUA released a Regulatory Alert reminding credit unions of the requirement to collect and report HMDA data during 2016. The credit union must collect HMDA data during 2016 if: Your credit union’s total assets as of December 31, 2015, exceed $44 million; Your credit union had a home or branch office in a Metropolitan Statistical Area … Read More

2016 NCUA Examination Focus

Akin to, the in-laws are coming, and they are bringing gifts… The NCUA issued Letter 16-CU-01 describing top areas of supervisory focus and will be part of the 2016 exam process.  The letter highlights: Cybersecurity Assessment NCUA encourages all credit unions to use the FFIEC tool to manage cybersecurity risks. NCUA also plans to begin incorporating the Cybersecurity Assessment Tool … Read More

Target Data Breach Settlement Website

A Target Data Breach Settlement website has been released providing information for financial institution class members of the Target data breach litigation. The website includes settlement terms, frequently asked questions, claim instructions and an on-line claim application. CLAIMS MUST BE FILED ONLINE (OR POSTMARKED FOR MAIL) ON OR BEFORE MARCH 22, 2016. If the credit union has not previously released … Read More