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

Same-day ACH Rule (NACHA)

The NACHA rule change will enable ACH Originators that desire same-day processing the option to send same-day ACH transactions to accounts at any receiving financial institution (RDFI). The Rule includes a “Same-Day Fee” on each same-day ACH transaction so that RDFIs would recover, on average, their costs for enabling and supporting same-day ACH. The Rule will enable the option for … Read More