Rural or Underserved Counties

The CFPB has published a list of counties that it determined to be “rural” or “rural or underserved” during 2016 for purposes of applying certain regulatory provisions related to mortgage loans during 2017. Mortgage rules that refer to these lists are: Escrow requirements under TILA/Regulation Z Ability to repay and qualified mortgage standards under TILA/Regulation Z High-cost mortgage and homeownership … Read More

CFPB Request for Information Regarding Consumer Access to Financial Records

The CFPB has launched a formal inquiry into obstacles consumers face in accessing and sharing with third parties personal financial records held by banks and other institutions. The action by the bureau comes amid banking industry concern over a commonly used process called “screen scraping” in which consumers provide their online banking credentials to a third-party app or tool. While … Read More

FFIEC Issues Uniform Interagency Consumer Compliance Rating System

The FFIEC, along with the banking brotherhood (FRB, CFPB, FDIC, NCUA, and OCC) released an updated Uniform Interagency Consumer Compliance (CC) Rating System.  The revisions to the CC Rating System were not developed to set new or higher supervisory expectations for financial institutions and their adoption will represent no additional regulatory burden.  Agencies will begin using the updated CC Rating … Read More

DCU’s Guide to Director Responsibilities

The DCU released Bulletin B-16-20, which is a white paper guide for credit union directors.  The guide, based on the FDIC’s Pocket Guide for Directors, is a set of common-sense principles setting forth the basic responsibilities and duties of a credit union’s board.  It describes a framework for corporate governance that can apply to any institution.  The DCU feels that … Read More

NCUA’s Basics of Data Processing Contracts Resource

The NCUA has released the Basics of Data Processing Contracts, which provides detailed, comprehensive instructions on negotiating contracts with third-party vendors for digital services.  The guidebook covers the elements of the contracting process, including: Requesting and evaluating bids; Performing due diligence on potential vendors; Negotiating terms, including pricing, performance requirements and liabilities; and Contract management and compliance. The guide comes … Read More

Repeal of Regulatory Relief for Small Credit Unions CR-102 Filed

The DCU is repealing its Regulatory Relief for Small Credit Unions rule (Chapter 208-424-WAC) because the rule no longer complies with the Washington Credit Union Act and is out of date.  For credit unions up to ten million dollars in total assets, the rule provides timing relief for special membership and regular board meetings. Passwords to access the blog posts, … Read More

Fall 2016 CFPB Supervisory Highlights

The CFPB released the Fall 2016 issue of its Supervisory Highlights.  Included are – Repossession fees and refusal to return property Supervision found that companies were holding borrowers’ personal belongings and refusing to return the property to borrowers until after the borrower paid a fee for storing the property. If borrowers did not pay the fee before the company was … Read More

IRS Waiver of 60-Day Rollover Requirement

Effective August 24, the IRS changed its appeals process for people who miss the 60-day deadline to rollover funds from a qualified plan or IRA.  The appeals process allows people to provide a self-certification that meets the requirements. For the purpose of accepting and reporting a rollover contribution into a plan or IRA, a plan administrator (credit union) may rely … Read More

2017 HMDA Data Submission Changes

The CFPB has posted information on changes to the submission process listed in the Filing Instructions Guide for HMDA data collected in 2017. Beginning with the HMDA data collected in 2017, filers will submit their HMDA data to the CFPB using a web interface referred to as the HMDA Platform. HMDA filers will interact directly with the HMDA Platform to file their HMDA data. … Read More

NCUA Renames Office of Consumer Protection

The National Credit Union Administration published at 81 FR 76495 a notice renaming its Office of Consumer Protection (OCP). The new name, effective today, is the Office of Consumer Financial Protection and Access (OCFPA). Passwords to access the blog posts, and blog posts are only for NWCG owners and retained clients. These should not be shared outside of the credit union. Blog … Read More