CFPB Supervisory Highlights – Winter 2020… and how CSG can help

In February, the CFPB released its 21st Supervisory Highlights Report. This report covered findings identified in examinations conducted by the CFPB between April 2019 and August 2019. Areas included in the report include mortgage servicing, payday lending (including general Regulation Z requirements), debt collection, and student loan servicing. Mortgage Servicing Highlights Regulation X violations discussed in the report include failing … Read More

NCUA SL 17-01 Updated Compliance Risk Indicators

On March 29, 2017, NCUA released a supervisory letter in a Letter to Credit Unions (17-CU-02) that provides an updated list of Compliance Risk Indicators. The updated list builds upon the previous guidance issued in a 2002 Letter to Credit Unions. NCUA notes that the “updated list of indicators does not impose any new or higher supervisory expectations to credit unions.” … Read More

DCU Bulletin B-17-06 Obtaining Audit Reports from Third-Party Providers

The Division of Credit Unions has published Bulletin B-17-06 regarding examiners obtaining audit reports from third-party providers. Annual audit reports are required for Federally Insured State Credit Union’s (FISCUs) with $500 million or more in assets. For those with less than $500 million, either of three supervisory committee audit options are available.   See:   §715.4   Audit responsibility of … Read More

NCUA Letter to Credit Unions 16-CU-07 Military Lending Act Examination

Starting October 3, 2016, credit unions must comply with the amended regulation the Department of Defense issued implementing the Military Lending Act. With this amended rule, NCUA intends to take the same examination approach used with the Consumer Financial Protection Bureau’s TILA-RESPA Integrated Disclosures rule in 2015 and its Qualified Mortgage and Ability-to-Repay rules in 2014. NCUA examiners are instructed … 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

FFIEC Proposed changes to the Consumer Compliance Rating System

The Federal Financial Institutions Examination Council (FFIEC) agencies issued a proposed rule updating the Uniform Consumer Compliance Rating System.  This System has been in place since 1980.   No action is required on the part of the credit union, as this is currently a proposed amendment, and if enacted, would not institute new supervisory expectations. The FFIEC will accept comments … Read More

DCU 2016 Exam Focus

The Division of Credit Unions has published Bulletin B-16-02, which establishes their exam focus for 2016. The bulletin lists four focus areas for 2016: Cybersecurity This goes hand-in-hand with NCUA’s focus of cybersecurity risks. The DCU hired Security Compliance Associates (SCA) to assist them in performing IT security examinations. The main differences that credit unions will see in the Division’s … Read More

2016 NCUA Examination Focus

Akin to, the in-laws are coming, and they are bringing gifts… The NCUA issued Letter 16-CU-01 describing top areas of supervisory focus and will be part of the 2016 exam process.  The letter highlights: Cybersecurity Assessment NCUA encourages all credit unions to use the FFIEC tool to manage cybersecurity risks. NCUA also plans to begin incorporating the Cybersecurity Assessment Tool … Read More