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

Marijuana Related Business – WA Exam Update

The DFI released updated examination procedures for marijuana related businesses directed to DCU examination staff. Included in the procedures is an appendix that focuses on pricing of accounts for, and lending to, marijuana related business accounts.  It is an eye-opening read for credit unions considering loaning to these businesses. In addition to the updated examination procedures, the DFI has a … Read More

PCI Data Security Standard Ver. 3.2 Released

The Payment Card Industry Data Security Standard (PCI DSS) was developed to encourage and enhance cardholder data security and facilitate the broad adoption of consistent data security measures globally. PCI DSS provides a baseline of technical and operational requirements designed to protect account data. PCI DSS applies to all entities involved in payment card processing—including merchants, processors, acquirers, issuers, and … Read More

CFPB Spring 2016 Rulemaking Agenda

The CFPB’s Spring 2016 Agenda has been published, and it looks like we may have a busy summer.  Compliance folks may want to get some sleep this weekend, because it may be your last chance.  Of the rules on the list, the following may have impact on credit unions. In the Prerule Stage: Business Lending Data (Regulation B) Section 1071 … Read More

Oregon – Semi-Annual Escrow Rate Adjustment

ORS 86.245 requires that Oregon State lenders who require security protection in connection with a real estate loan to pay interest on funds in an escrow account of at least the discount rate.  The rate is adjusted semiannually, and calculated on May 15 and November 15, and covers the following six-month period.  The discount rate is calculated by the most recent … Read More