1041 Payday, Auto Title, and Balloon-Payment Loans Rule

On October 5, 2017, the CFPB released its anticipated 1690-page Rule regarding payday, auto title, and balloon-payment loans.  The Rule, while pared down from the June 2016 CFPB’s proposed rule, still covers the ability-to-repay and underwriting requirements, payment restrictions and requirement, and new information reporting for covered loans.  (A version of the Rule, with Official Interpretations incorporated is available here.) … Read More

Technical Amendments to the Beneficial Ownership Rule

FinCEN released technical amendments to its Beneficial Ownership Rule, as part of its Customer Due Diligence requirements effective May 11, 2018.  Part of the amendments update the Beneficial Owner Certification Form.  We have updated our version, available here, for institutions to use.  (Note, we have recently switched web hosts, and are experiencing bugs, while everything gets transferred over.  At this … Read More

Customer-Authorized Financial Data Sharing and Aggregation

The CFPB released its outline of principles for protecting consumers when they authorize third party companies to access their financial data to provide certain financial products and services (think – digital wallets).  The principles are intended to help foster the development of innovative financial products and services, increase competition in financial markets, and empower consumers to take greater control of their … Read More

Updated TRID Small Entity Compliance Guide

The CFPB released version 5.0 of the TILA-RESPA Integrated Disclosure Rule Small Entity Compliance Guide. The revised version incorporates the recent amendments to the rule that became effective on October 10, 2017.  Compliance with the amendments will be required for applications received on or after October 1, 2018. Updates to the Guide include: requirements and guidance on current requirements for tolerances in the good … Read More

DCU Bulletin B-17-16

October 9, 2017 Electronic Exam Report Transmission The Division of Credit Unions (Division) is pleased to announce the transition of sending all examination reports through encrypted email for a more efficient process. The Division will begin sending all examination reports electronically beginning on November 1, 2017. If your credit union is unable to receive encrypted email with attachments, please contact … Read More

CFPB HMDA Implementation Materials

The CFPB has updated their cart Collection and Reporting of HMDA Information about Ethnicity and Race.  Additionally, the CFPB has published a new chart, Reportable HMDA Data: A Regulatory and Reporting Overview Reference (“Reporting Reference Chart”) intended to be used as a reference for data points required to be collected, recorded, and reported under Regulation C. The Reporting Reference Chart … Read More

FDIC Releases Interagency Designated Key HMDA Data Fields List

From FIL-51-2017: Summary: The Board of Governors of the Federal Reserve System (FRB), the Federal Deposit Insurance Corporation (FDIC), and the Office of the Comptroller of the Currency (OCC) are issuing designated key Home Mortgage Disclosure Act (HMDA) data fields to support the efficient and effective evaluation of financial institutions’ compliance with HMDA’s requirements. Statement of Applicability to Institutions With … Read More

Proposed NCUA Advertising Rule

The NCUA proposed changes to its advertising requirements under 740.5, which includes: Removing the requirement to include the official advertising statement on annual reports and statements of condition; Allowing the use of another short title “Insured by NCUA”; Increasing the exemption from 15 seconds to 30 seconds for radio and television advertisements. Comments are due by December 4, 2017 740.5 … Read More