Joint Statement on Cyber Attacks Involving Extortion

The FFIEC issued a Statement notifying financial institutions of the increasing frequency and severity of cyber attacks involving extortion. The Statement does not contain any new regulatory expectations. Credit unions should develop and implement effective programs to ensure they are able to identify, protect, detect, respond to, and recover from these types of attacks. The Statement recommends that financial institutions … Read More

NCUA Releases Cybersecurity Video

The video provides an overview of how the assessment tool works. The assessment tool can help credit unions pinpoint strengths and weakness in their cyber security programs. “The increasing volume and sophistication of cyber threats pose real risks to the credit union system,” NCUA Board Chairman Debbie Matz said. “NCUA has created this new video to supplement the online information … Read More

Risk-Based Capital Rule

The NCUA released its final rule on risk-based capital requirements. Complex credit unions (those over $100 million in total assets as of its latest Call Report) will be required to calculate their risk-based capital ratio instead of its net worth to determine capital adequacy. Recommended Actions: In preparation for the rule’s effective date of January 1, 2019, credit unions with … Read More

Regulation C – HMDA Reporting Final Rule

The CFPB released the final rule amending and expanding reporting requirements under Regulation C and the Home Mortgage Disclosure Act.  The 797 page rule includes the threshold for covered institution reporting, changes to covered transactions, requirements for large volume reporters, new reporting procedures, disclosure and privacy, along with new and modified data fields. Dates: Most provisions of the final rule … Read More

Changes to Information Technology Exams

The DCU has outsourced parts of its credit union IT exams to Security Compliance Associates (SCA) from November 2015 through June 2017. The Bulletin states more resources and hours will be devoted to IT examinations (i.e. one to two additional days will be added to the standard IT exams beginning in 2016). Examination hours will be scaled either down or … Read More

NACHA Third-Party Sender Registration Proposed Rule

The proposed rule would apply to Third-Party Senders that are the ODFI’s direct customers, as well as those other Third-Party Senders that are direct customers of the first Third-Party Sender, otherwise known as “nested” Third-Party Senders (The rule would also apply regardless of whether the ODFI allows the Third-Party Sender Direct Access to an ACH Operator. In the case of … Read More

CFPB Provides Guidance About Marketing Services Agreements

The CFPB issued a bulletin providing guidance to the mortgage industry regarding marketing services agreements. The bulletin offers an overview of the federal prohibition on mortgage kickbacks and referral fees, and describes examples from the Bureau’s enforcement experience as well as the risks faced by lenders entering into these agreements. During the course of supervising mortgage lenders and enforcing federal … Read More

Proposed Rule prohibiting arbitration clauses for group actions

The CFPB is considering proposing a rule that would ban consumer financial companies, including banks and credit unions, from clauses requiring arbitration, that are used to block class action lawsuits. The proposals under consideration would prohibit companies from blocking group lawsuits through the use of arbitration clauses in their contracts.  This would apply generally to the consumer financial products and … Read More

CFPB Readiness Guide for mortgage rule changes

The CFPB released an updated Readiness Guide that includes the October 3, 2015 effective date for the Know Before you Owe mortgage disclosure rule.  The update offers guidance on how to evaluate readiness for complying with the mortgage rules changes.  The guide includes a Readiness Questionnaire (beginning on page 10) to serve as a guide in preparing for the mortgage … Read More