Amendments relating to small creditors and rural or underserved areas under the Truth in Lending Act

The CFPB issued a final rule, Amendments Relating to Small Creditors and Rural or Underserved Areas under the Truth in Lending Act (Rule). The Rule revises the Regulation Z definitions of “small creditor” and “rural area,” and makes technical changes and clarifications to other sections of Regulation Z and the related commentary. The revised definitions will affect the availability of … Read More

NCUA Consumer Complaint Portal

On September 10, 2015 the NCUA released a complaint site on its Consumer Assistance Center portal located at MyCreditUnion.gov. Consumers are able to submit inquiries, complaints and additional documentation online through a secure portal. Consumers will also be able to check the status of their complaints. NCUA also implemented new complaint resolution procedures that improve and streamline how the agency … Read More

NCUA Civil Money Penalties Inflation Adjustment

The NCUA adjusted civil money penalties for violations within its jurisdiction to account for inflation. Federal agencies must adjust civil money penalties at least once every four years to account for inflation. Dates: Effective:  09/23/2015 Recommended Actions: The adjustment should not impact the operations of the credit union, but the credit union should be aware of the increase penalties for … Read More

Regulation Z Annual Loan Threshold Adjustments

Dates: Effective January 1, 2016 Summary: The CFPB announced the 2016 thresholds for Regulation Z provisions governed by the CARD Act, the Home Ownership and Equity Protection Act and the Dodd-Frank Act. Recommended Actions: Credit unions should review the new limits and incorporate them into their policies and procedures. Detailed Analysis: CARD Act Annual Adjustments: The safe harbor penalty fees … Read More

NMLS Renewal

The NMLS annual renewal period for MLOs is from November 1 to December 31.  Both the credit union and mortgage loan originators must renew during this period.  The NMLS provides this page with guidance on the renewal process and includes batch upload instructions for MLOs associated with the credit union.  If the credit union has merged with another institution during … Read More

Consumer Compliance Outlook

The Federal Reserve released the 7th Anniversary Issue of the Consumer Compliance Outlook.  The issue only contains one article, entitled Managing Risk Throughout the Product Life Cycle and it describes a product-focused risk management framework largely through a UDAAP lens, which may be especially useful for credit unions considering the introduction of new products and services. As UDAAP enforcement actions by … Read More

Complying with the Military Lending Act

The Military Lending Act (MLA), along with the Servicemember’s Civil Relief Act (SCRA), provides protections to our servicemembers.  Both of these Acts were developed to help ease the legal and financial burdens on servicemembers actively serving our country and allow them to focus on their duties. The MLA came as result of the Talent-Nelson Amendment to the John Warner Defense … Read More

Odd Ducks

While watching television this past weekend I was bombarded by commercials for insurance companies and medicines.  We may think that banking advertisements have too many disclosure requirements but these surpass us by far.  Of course, I had to get up and stand right next to the television to see the fine-print, and pause the commercials in order to have time … Read More

Where does your compliance fit?

In order to cut expenses, credit unions have merged jobs and duties to the point that Compliance may oversee, or be part of, other departments or business units.  This is akin to putting the kids in charge of the cookies.   In order to develop or provide services to members, the compliance function may take a back seat to the sales … Read More