FIN-2016-A005 Cyber-Events and Cyber-Related Crime Reporting

On October 25, 2016, FinCEN released FIN-2016-A005, Advisory to Financial Institutions on Cyber-Events and Cyber-Enabled Crime. It serves as a refresher of the credit union’s SAR filing obligations when encountering cyber-events. A financial institution is required to report a suspicious transaction conducted or attempted by, at, or through the institution that involves or aggregates to $5,000 or more in funds … Read More

NCUA Letter to Credit Unions 16-CU-07 Military Lending Act Examination

Starting October 3, 2016, credit unions must comply with the amended regulation the Department of Defense issued implementing the Military Lending Act. With this amended rule, NCUA intends to take the same examination approach used with the Consumer Financial Protection Bureau’s TILA-RESPA Integrated Disclosures rule in 2015 and its Qualified Mortgage and Ability-to-Repay rules in 2014. NCUA examiners are instructed … Read More

NCUA Letter to Credit Unions 16-CU-08 Interest Rate Risk

Effective January 1, 2017, NCUA will institute changes to the agency’s interest rate risk review procedures and adopt a standardized measurement of interest rate risk to scope and rate interest rate risk assessments more efficiently and effectively. Field staff will implement these changes using the enclosed Interest Rate Risk Review Procedures Workbook and Guide to Using NCUA’s Interest Rate Risk … Read More

FFIEC Cybersecurity Assessment Tool FAQs

The FFIEC released a Frequently Asked Questions Guide related to the Cybersecurity Assessment Tool (CAT). The FFIEC published the Cybersecurity Assessment Tool in June of 2015 as a voluntary tool to help financial institutions’ management identify risk and determine their cybersecurity preparedness. The CAT provides a repeatable and measurable process that financial institutions may use to measure their cybersecurity preparedness … Read More

DCU Bulletin B-16-18

On October 12, 2016, the DCU released Bulletin B-16-18, Indirect Lending and Credit Tier Exceptions.  The Bulletin includes credit risk concerns and fair lending risks. The Bulletin addresses concerns with indirect lending procedures and practices which allow underwriters to bump a vehicle loan applicant to a higher credit tier and interest rate that is more favorable to the applicant when … Read More

DCU Bulletin B-16-17 Guidance on Money Service Businesses

On September 30, the DCU released Bulletin B-16-17, which provides Guidance on Money Service Businesses (MSBs). Operation Choke Point, and additional pushing from regulators, urged financial institutions to avoid offering services to specific businesses identified as high risk – such as money service businesses.  In late 2014, the DOJ and FDIC determined that they should not be doing this, and … Read More

CFPB Notice of Public List of Companies Offering Free Credit Score

On October 5, the CFPB released a notice that they intend to publish a list of companies that provide free access to credit scores. Financial institutions, credit card issues, and other companies may offer consumers free access to a credit score giving consumers an important tool to manage their financial lives.  The Office of Financial Education of the CFPB would … Read More

Final Prepaid Account Rules Released

On October 4, the CFPB released its final rule for prepaid cards.  The rule will cover traditional prepaid cards, general-purpose reloadable cards, mobile wallets, person-to-person payment products, and other electronic prepaid accounts that can store funds.  Payroll cards, student financial aid disbursement cards, tax refund cards, and certain federal, state, and local government benefit cards such as those used to … Read More