2017 Exam Focus

The NCUA released Letter No. 17-CU-01, which describes their supervisory priorities for 2017. The primary areas of focus are: Cybersecurity Assessment. Credit unions are encouraged to use the Cybersecurity Assessment Tool, and examiners will continue to evaluate the credit unions’ cybersecurity risk management practices. Bank Secrecy Act Compliance. As always, BSA is a hot topic. Additional focus will be on … Read More

Risk-Based Exam Scheduling

On December 28, 2016, the NCUA released Letter to Credit Unions 16-CU-12, detailing their exam scheduling policy which goes into effect January 1, 2017. For state-charted, federally insured credit unions, the Letter details that: Credit unions meeting any one of the following three criteria will receive NCUA exams that will begin between 8 and 12 months from the prior examination … Read More

FFIEC Issues Uniform Interagency Consumer Compliance Rating System

The FFIEC, along with the banking brotherhood (FRB, CFPB, FDIC, NCUA, and OCC) released an updated Uniform Interagency Consumer Compliance (CC) Rating System.  The revisions to the CC Rating System were not developed to set new or higher supervisory expectations for financial institutions and their adoption will represent no additional regulatory burden.  Agencies will begin using the updated CC Rating … Read More

DCU’s Guide to Director Responsibilities

The DCU released Bulletin B-16-20, which is a white paper guide for credit union directors.  The guide, based on the FDIC’s Pocket Guide for Directors, is a set of common-sense principles setting forth the basic responsibilities and duties of a credit union’s board.  It describes a framework for corporate governance that can apply to any institution.  The DCU feels that … Read More

August Compliance Recap

August’s compliance recap, with a summary of regulatory issues that might impact the credit union, is available here.

Update to Consumer Complaint Process for Washington State

The Division of Credit Unions released Bulletin B-16-10 to announce that they will be transitioning to encrypted emails for notifying credit unions of filed complaints. Credit unions should submit point of contacts to receive complaint notifications from the DCU by September 15, as instructed in the Bulletin. Consumer Complaints – Electronic Communication The Division of Credit Unions (Division) is pleased … Read More

Proposed Amendments to Regulation Z Mortgage Disclosure Requirements

The CFPB issued proposed changes to amend the KBYO/TRID rules of Regulation Z.  The CFPB states that the proposed amendments memorialize its informal guidance on various issues and includes clarifications and technical amendments.  There are a number of proposed changes in proposal, but are not intended to revisit major policy decisions so soon after the October 2015 effective date. Comments … Read More

Semiannual Risk Perspective

The OCC released its Semiannual Risk Perspective for Spring 2016, which reveals that strategic, credit, operational, and compliance risk remain top concerns, with interest risk following closely. While the OCC is not a regulatory agency for credit unions, it does oversee national banks and federal savings associations, and provides a perspective on industry trends. The report highlights key risk issues … Read More

Online Payment Process for DCU Semi-Annual Asset Assessment Fees

Online Payment Process for DCU Semi-Annual Asset Assessment Fees DCU Bulletin B-16-09, July 7, 2016 Chapter 31.12 RCW authorizes the Director to charge fees to credit unions and certain other persons in order to cover the costs of the operation of the division of credit unions and to establish a reasonable reserve for the division. Chapter 208-418 WAC is amended … Read More

Proposed Payday Loan Rule – Part 1

The CFPB released its Proposed Payday, Vehicle Title, and Certain High-Cost Installment Loans Rule on June 2, in coordination with a field hearing on these small-dollar loans.  The 1333 page proposal aims to end payday debt traps, where borrowers seeking a short-term cash fix are saddled with loans they cannot afford and sink into long-term debt. Because of the scope … Read More