Requirements for Consumer Authorizations for Preauthorized Electronic Fund Transfers

The CFPB has posted an article and announced its issuance of Bulletin 2015-06 on automatic debits. The article explains to consumers the way an auto debit to a financial institution account works and the protections for the account owner, and provides links to action letter templates consumers can use to invoke those protections. The Bulletin alerts companies that they must … Read More

FDIC Cybersecurity Resources

The FDIC provides cybersecurity awareness resources for financial institutions that credit unions can use to assess their risks and responses to threats. Within these, is a Community Bank Cyber Exercise that includes videos depicting unique security scenarios. The videos provide discussion topics on operational risk issues and the potential impact of information technology disruptions on common banking functions. The series … Read More

CFPB Fall Rulemaking Agenda

The CFPB published its Fall Rulemaking Agenda that outlines actions in pre-rule, proposed rule, long-term, and completed stages.  The Agenda provides an insight as to where the CFPB is headed. Current Initiatives: Arbitration – The CFPB is beginning a rulemaking process to address concerns related to the use of arbitration agreements in connection with credit cards, deposit accounts, payday loans … 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

Reserve Requirement Adjustment for Depository Institutions – Regulation D

>The Federal Reserve amended Regulation D to reflect the annual indexing of reserve requirements for 2016. Reserve Liability Reserve Requirement Net Transaction Accounts:   $0 to $15.2 million (from $14.5 million) 0% of amount   $15.2 million to $110.2 million (from $103.6 million) 3% of amount   Over $110.2 million $2,850,000 + 10% of the amount over $110.2 million Nonpersonal … Read More

ACH Unauthorized Entry Fee

The Rule is intended to improve ACH Network quality by reducing the incidence of ACH debits that are returned as unauthorized. Under this Rule, an ODFI will pay a fee to the RDFI for each ACH debit that is returned as unauthorized (return reason codes R05 reserved, R07 authorization revoked by customer, R10 customer advises not authorized; ineligible, notice not … Read More

New NCUA Consumer Assistance Center Portal Open to Credit Unions

Portal will Streamline Complaint Process; Use is Voluntary; Registration Required Credit unions can now resolve consumer complaints more efficiently through the National Credit Union Administration’s Consumer Assistance Center online portal, the agency announced today. Credit unions can now use the portal, located on NCUA’s MyCreditUnion.gov site, to receive correspondence from the Consumer Assistance Center about complaints concerning them, to send … Read More

Delay in Overtime Pay Rule Release

On July 6, 2015, the Department of Labor released its proposal to update overtime pay rules. Currently, in order to be considered exempt from overtime pay, employees must meet certain minimum tests related to their primary job duties and be paid on a salary basis not less than $23,660 annually. The proposal rule raises the threshold to $47,892 annual. The … Read More

FFIEC Revised Management Booklet

The Federal Financial Institutions Examination Council (FFIEC) members issued a revised Management booklet, which is part of the FFIEC Information Technology Examination Handbook (IT Handbook). The Management booklet, including the examination procedures, has been substantially revised. The booklet outlines the principles of sound governance and, more specifically, information technology (IT) governance. The booklet explains how IT risk management relates to … Read More

Automated Cybersecurity Tool

The Financial Services Sector Coordinating Council has developed and made available an Automated Cybersecurity Assessment Tool that that can be used in conjunction with the FFIEC’s assessment tool. It is in a user-friendly Excel spreadsheet that provides risk criteria and cybersecurity maturity levels, then presents those results in graphs and charts to better illustrate where users need to focus efforts … Read More