Last year the CFPB suspended the requirement to submit credit card agreements to the Bureau. This temporary suspension is expiring at the end of April, and credit unions that have more than 10,000 credit card accounts will need to begin submitting their agreements quarterly, with the first due to the Bureau on or before May… Read More »
In response to the Helping Expand Lending Practices in Rural Communities (HELP) Act, the CFPB issued an Interim Final Rule, which expands eligibility for the special provisions allowing balloon-payment qualified mortgages and balloon-payment high-cost mortgages and for the escrow exemption. Pursuant to the Interim Final Rule, a small creditor is no longer required to extend… Read More »
The Advisory and Report contains recommendations for banks and credit unions to use to aid in preventing, recognizing, reporting, and responding to financial exploitation of older Americans. The recommendations are voluntary, and do not represent any new requirements. The Advisory and Report contains recommendations for banks and credit unions to use to aid in preventing,… Read More »
Functionalities that make prepaid cards attractive to consumers also pose risks for financial institutions that issue prepaid cards and process prepaid card transactions. For example, easy access to prepaid cards, the ability to use them anonymously, and the potential for relatively high volumes of funds to flow through pooled prepaid access accounts, make prepaid cards… Read More »
The Department of Labor Issued its Final Rule Regarding Procedures for Handling Employee Retaliation Complaints under the Employee Protection Provision of the Consumer Financial Protection Act A covered person (offers or provides consumer financial products or services) cannot retaliate against an employee for: (1) reporting to a governmental authority or law agency information that the… Read More »
Reprinted from ABCnews (03/16/16): Identity theft is a growing problem across the nation, and Manhattan’s top district attorney says that bank tellers are increasingly involved, adding that his office prosecutes one case per month involving tellers. The tellers in question are part of larger identity theft rings, District Attorney Cyrus Vance said in a recent… Read More »
Reprinted from Fedflash Effective September 23, 2016, with Phase 1 implementation of the Same Day ACH Rules change, a current-day or stale-day date in the effective entry date field of a credit entry will trigger same-day processing (provided the other requirements are also met). Every Automated Clearing House (ACH) network participant should be aware of… Read More »
The Final MBL Rule provides credit unions making business loans with greater flexibility and more autonomy, shifting the rule’s focus from the current prescriptive approach to a more principles-based methodology that emphasizes sound risk management practices for business lending. The final Rule eliminates most of the prescriptive lending limits and their corresponding waiver provisions. The… Read More »
NCUA released Regulatory Alert 16-RA-04 providing guidance on complying with the changes to the Military Lending Act requirements. The guidance, Complying with Recent Changes to the Military Lending Act Regulation, provides a good overview of the changes, and the steps that the credit union will have to take. Along with an overview of the changes,… Read More »
FinCEN’s penalty assessment against Gibraltar Private Bank reads like a Stephen King novel for BSA compliance officers. The ongoing deficiencies and either the willful blindness or ignorance by Gibraltar caused me heartburn just reading the assessment report. Gilbraltar’s issues have been ongoing since at least 2010, when the OCC first warned Gibraltar of its BSA… Read More »
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