Marijuana Related Business – WA Exam Update

The DFI released updated examination procedures for marijuana related businesses directed to DCU examination staff. Included in the procedures is an appendix that focuses on pricing of accounts for, and lending to, marijuana related business accounts.  It is an eye-opening read for credit unions considering loaning to these businesses. In addition to the updated examination procedures, the DFI has a … Read More

PCI Data Security Standard Ver. 3.2 Released

The Payment Card Industry Data Security Standard (PCI DSS) was developed to encourage and enhance cardholder data security and facilitate the broad adoption of consistent data security measures globally. PCI DSS provides a baseline of technical and operational requirements designed to protect account data. PCI DSS applies to all entities involved in payment card processing—including merchants, processors, acquirers, issuers, and … Read More

CFPB Spring 2016 Rulemaking Agenda

The CFPB’s Spring 2016 Agenda has been published, and it looks like we may have a busy summer.  Compliance folks may want to get some sleep this weekend, because it may be your last chance.  Of the rules on the list, the following may have impact on credit unions. In the Prerule Stage: Business Lending Data (Regulation B) Section 1071 … Read More

Oregon – Semi-Annual Escrow Rate Adjustment

ORS 86.245 requires that Oregon State lenders who require security protection in connection with a real estate loan to pay interest on funds in an escrow account of at least the discount rate.  The rate is adjusted semiannually, and calculated on May 15 and November 15, and covers the following six-month period.  The discount rate is calculated by the most recent … Read More

DOL Final Rule – Overtime and Exempt Status

The Department of Labor released its Final Rule regarding overtime and exempt status for executive, administrative, and professional employees.  As a result, effective December 1, 2016, the credit union can no longer consider employees making less than $47,476 annually as exempt from overtime pay. Credit Union Action Required Effective December 1, 2016, the credit union can no longer consider employees … Read More

Interagency Guidance Regarding Deposit Reconciliation Practices

On May 18th, the Banking Brotherhood (Federal Reserve System, CFPB, FDIC, NCUA and OCC) released guidance for institutions regarding deposit reconciliation practices. If you recall, last year the CFPB, OCC, and FDIC took action against Citizens Bank for failing to credit consumers the full amounts of their deposited funds.  “Citizens Bank regularly denied customers the full credits of their deposits … Read More

Elder Financial Exploitation Webinar

If it’s free, it’s me… On Wednesday, May 25 at 11:00, the CFPB will hold a webinar on how financial institutions can protect older consumers from financial exploitation.  The presentation will highlight a recent CFPB report, Recommendations and Report for Financial Institutions on Preventing and Responding to Elder Financial Exploitation.  We blogged about the report here: Credit unions can … Read More

Website Accessibility & ADA

The Department of Justice released a Supplemental Advance Notice of Proposed Rulemaking relating to website accessibility for state and local government entities – public entities. The proposal does not affect credit unions, but may be a harbinger of things to come. The DOJ previously announced that they are reviewing requirements for websites, and plan on staggering proposed requirements. The first … Read More

Washington Uniform Power of Attorney Act

The Washington State Legislature passed Senate Bill 5635, which repeals the Washington State Power of Attorney Act and replaces it with a slightly modified Uniform Power of Attorney Act. The Act is effective January 1, 2017. Credit unions should: Review the new allowances and requirements for POAs created after January 1, 2017 Plan on using the new Certification form beginning … Read More

Beneficial Owner Verification Requirements

FinCEN released a Final Rule under the Bank Secrecy Act, which imposes specific requirements for financial institutions to identify and verify the identity of beneficial owners of legal entity customers when opening a new account. Beneficial owner – is either an individual who directly or indirectly owns 25 percent or more of the equity interest of a legal entity customer, … Read More