Federal Credit Union Fixed Assets Proposal

The NCUA proposed an amendment to the fixed-assets regulation that eliminates the requirement that a federal credit union must plan for, and eventually achieve full occupancy of acquired premises.  If passed, the credit union must partially occupy (at least 50% by the federal credit union or the federal credit union and a CUSO) within a reasonable period, but no later … Read More

Proposed Incentive-Based Compensation Arrangements

Section 956 of the Dodd-Frank Act requires the banking agencies (NCUA, FDIC, Federal Reserve System, Federal Housing Finance Agency, OCC, and the SEC) to jointly prescribe regulations or guidelines to prohibit incentive-based payment arrangements that the agencies determine to encourage inappropriate risks by providing excessive compensation or that could lead to material financial loss. Section 956 also requires that the … Read More

Quickies 4/13/16

NCUA posts report on serving the credit-invisible “Serving the Credit-Invisible,” a new report posted by the NCUA, explains how credit unions can build loan programs based on sound underwriting, appropriate risk management, loan monitoring and staff training that can help them reach this underserved population. The report details how to evaluate a loan applicant who is “credit-invisible” and describes best … Read More

Fair Credit Reporting Act Disclosures and Indirect Automobile Lending

Credit unions should either retain copies of provided Risk Based Pricing Notices in loan files or perform due diligence on automobile dealers to confirm they are providing the notices in a timely manner to the credit union’s indirect borrowers. The Division of Credit Unions released Bulletin B-16-04 providing guidance for state-chartered credit unions on indirect lending compliance requirements – specifically … Read More

Oregon Marijuana Banking Bill – Updated

Updated:  On April 4, 2016, Governor Brown signed the law, and it is now effective. House Bill 4094 was passed by both the House and Senate, and now awaits Governor Brown’s signature. This provides financial institutions with an exemption from Oregon State criminal law for providing financial services to legal marijuana related services – possessing, delivering, or manufacturing marijuana or marijuana-derived … Read More

SCRA Foreclosure Protection Relapses to 90 days – UPDATED

UPDATED On March 31, President Obama signed into law the “Foreclosure Relief and Extension of Servicemembers Act of 2015,” extending the sunset date to December 31, 2017.  Credit union’s SCRA Notices should (again) reflect one-year, rather than 90 days.   The Service Members Civil Relief Act provides protection for service members from foreclosure for a period of time after the end … Read More

Emergency Communications System

The DCU encourages credit unions to register and participate in the Emergency Communication System (ECS) that the Federal Reserve provides. Bulletin B-16-05 provides that the ECS is a free service provided by the Federal Reserve that will enable DFI to communicate with your financial institution in the event of a natural or man-made disaster, or events that dramatically affect the … Read More

Rulemaking on Amendments to the Member Business Loan Rule

The DCU released Bulletin B-16-06, announcing that they intend to modernize the state MBL rule (Chapter 208-406 WAC) and provide similar authority as authorized for federal chartered credit unions. Rulemaking will begin in April, with meetings held over the next several months.  The tentative schedule includes meetings through August. You can attend rulemaking in person or by teleconference.  The DCU … Read More