MLA Interpretive Rule

The Department of Defense released its anticipated Guidance in regards to the new Military Lending Act requirements, effective October 3, 2016.  The Guidance is in the form of questions and answers, which are replicated below.  The Guidance is an Interpretive Rule, and will be published in the Federal Register and effective August 26, 2016. While the questions do address whether the … Read More

Student Loan Servicing – Fix It Form

The CFPB has developed a “Fix It Form” that credit unions that service student loans may see. On August 18, the CFPB released the Form, along with a press release and the Loan Ombudsman’s Midyear Report, in response to complaints borrowers have with using income-driving repayment plans tied to their federal student loans. The press release and report summarizes complaints … Read More

Military Lending Act – Are You Ready?

Compliance with the Military Lending Act changes will go into effect on October 3 (credit card compliance is not until October 3, 2017), and many credit unions are still trying to work out the details.  The Department of Defense has repeatedly promised guidance, but has not yet delivered.  Needless, the credit union must comply with the requirements beginning next month.  … Read More

June Monthly Recap

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

Payday Loan Rule – Part 4 of 3; Submitting Comments

Payday Loan Rule – Part 4 of 3, Submitting Comments The CFPB is accepting comments on its proposed Payday, Vehicle Title, and Certain High-Cost Installment Loans Rule, released June 2, 2016.  Comments on the proposed rule must be submitted by September 14, 2016. You may submit comments, identified by Docket No. CFPB-2016-0025 or RIN 3170–AA40, by any of the following … Read More

Proposed Payday Loan Rule – Part 3

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

Consumer Compliance Outlook – Card Disputes

The latest issue of Consumer Compliance Outlook, published by the Federal Reserve, contains an informative article discussing when Regulation E and Regulation Z come into play in regards to consumers disputing transactions with merchants.  The article states Under Regulation Z, credit card issues have two separate legal obligations that could apply to merchant disputes.  In contrast, under Regulation E, debit … Read More

Proposed Payday Loan Rule – Part 2

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

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

Quickies 4/13/16

NCUA posts report on serving the credit-invisible “Serving the Credit-Invisible,” a new report posted by the NCUA, explains how credit unions can build loan programs based on sound underwriting, appropriate risk management, loan monitoring and staff training that can help them reach this underserved population. The report details how to evaluate a loan applicant who is “credit-invisible” and describes best … Read More