SBA Proposed Rule

The Small Business Administration is issuing a proposed rule amending several regulations relating to the 7(a) and 504 loan programs used by banks. The proposed changes are intended to streamline SBA processes and update or remove outdated provisions – for example, by replacing the Certified Lenders Program with SBA “delegated authority” criteria. The proposed changes include redefining cooperative businesses as … Read More

Going Digital: Strategies for Providing Digital Services

NCUA’s Office of Small Credit Union Initiatives issued “Going Digital:  Strategies for Providing Digital Services,” which provides step-by-step instructions on creating a strategic plan for analyzing members’ needs and tailoring digital products to meet those needs.  The guidebook also details potential advantages and disadvantages to members and credit unions. While most of our credit unions provide a wide array of … Read More

The FDIC’s Story on Data Breach Response

The FDIC has been plagued with a number of data breaches recently, and a congressional report details the story and facts, along with FDIC’s cooperation (or lack of), relating to two breaches caused by separating employees removing confidential information.  The report is an interesting read, and provides a lot of how-not-to report and respond. The report details one story and … Read More

Semiannual Risk Perspective

The OCC released its Semiannual Risk Perspective for Spring 2016, which reveals that strategic, credit, operational, and compliance risk remain top concerns, with interest risk following closely. While the OCC is not a regulatory agency for credit unions, it does oversee national banks and federal savings associations, and provides a perspective on industry trends. The report highlights key risk issues … Read More

Online Payment Process for DCU Semi-Annual Asset Assessment Fees

Online Payment Process for DCU Semi-Annual Asset Assessment Fees DCU Bulletin B-16-09, July 7, 2016 Chapter 31.12 RCW authorizes the Director to charge fees to credit unions and certain other persons in order to cover the costs of the operation of the division of credit unions and to establish a reasonable reserve for the division. Chapter 208-418 WAC is amended … Read More

Regulation P Proposed Amendment

On July 1, the CFPB released proposed amendments to Regulation P, to align the regulation with the changes to the GLBA that took place last year.  If you remember, in December 2015, the GLBA was amended to provide an exemption to financial institutions from the requirement to provide an annual privacy notice.  If the institution does not allow the customer … Read More

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