June Monthly Recap

June’s compliance recap, with a summary of regulatory issues that might impact the credit union, is available here.

Current Expected Credit Losses

On June 16, the Financial Accounting Standards Board (FASB) issued its final standard on credit losses; the Current Expected Credit Losses (CECL) model.  The standard follows a Life of Loan Concept that allows financial institutions to leverage its current internal credit risk systems as a framework for estimating expected credit losses.  The standard requires organizations to measure all expected credit … Read More

Payday Loan Rule – Part 4 of 3; Submitting Comments

Payday Loan Rule – Part 4 of 3, Submitting Comments The CFPB is accepting comments on its proposed Payday, Vehicle Title, and Certain High-Cost Installment Loans Rule, released June 2, 2016.  Comments on the proposed rule must be submitted by September 14, 2016. You may submit comments, identified by Docket No. CFPB-2016-0025 or RIN 3170–AA40, by any of the following … Read More

Proposed Payday Loan Rule – Part 3

The CFPB released its proposed Payday, Vehicle Title, and Certain High-Cost Installment Loans rule on June 2, in coordination with a field hearing on these small-dollar loans.  The 1333 page proposal aims to end payday debt traps, where borrowers seeking a short-term cash fix are saddled with loans they cannot afford and sink into long-term debt. Because of the scope … Read More

Consumer Compliance Outlook – Card Disputes

The latest issue of Consumer Compliance Outlook, published by the Federal Reserve, contains an informative article discussing when Regulation E and Regulation Z come into play in regards to consumers disputing transactions with merchants.  The article states Under Regulation Z, credit card issues have two separate legal obligations that could apply to merchant disputes.  In contrast, under Regulation E, debit … Read More

Call Report Modernization – Request for Information

The National Credit Union Administration (NCUA) is conducting a comprehensive review of two vehicles used to collect information for regulatory oversight of federally insured credit unions (FICUs)—the 5300 Call Report (Call Report) and Form 4501A Profile (Profile). The overarching goal is modernizing content to (i) strengthen on-site examination and off-site monitoring by NCUA and state supervisory authorities, (ii) facilitate richer … Read More

FFIEC Issues Statement on Safeguarding the Cybersecurity of Interbank Messaging and Payment Networks

The Federal Financial Institutions Examination Council (FFIEC) members today advised financial institutions, consistent with existing regulatory expectations, to actively manage the risks associated with interbank messaging and wholesale payment networks. In a statement, the FFIEC also stressed that financial institutions should review risk-management practices and controls related to information technology systems and wholesale payment networks, including risk assessment; authentication, authorization … Read More

Proposed Payday Loan Rule – Part 2

The CFPB released its proposed Payday, Vehicle Title, and Certain High-Cost Installment Loans rule on June 2, in coordination with a field hearing on these small-dollar loans.  The 1333 page proposal aims to end payday debt traps, where borrowers seeking a short-term cash fix are saddled with loans they cannot afford and sink into long-term debt. Because of the scope … Read More

Proposed Payday Loan Rule – Part 1

The CFPB released its Proposed Payday, Vehicle Title, and Certain High-Cost Installment Loans Rule on June 2, in coordination with a field hearing on these small-dollar loans.  The 1333 page proposal aims to end payday debt traps, where borrowers seeking a short-term cash fix are saddled with loans they cannot afford and sink into long-term debt. Because of the scope … Read More

CFPB Supervisory Highlights

The CFPB released its 10th Supervisory Highlights, which focuses on consumer reporting, mortgage origination, fair lending, debt collection, remittances and student loan servicing. The credit union’s compliance and auditing staff should review the report to make sure that the credit union does not end up as a “highlight.” A couple of the highlights include: Consumer Reporting The Bureau found that … Read More