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

CECL Resources

From NAFCU ( A newly released, NAFCU-sponsored study outlines some of the key qualities and trade-offs for a variety of models for implementation of the Financial Accounting Standards Board’s current expected credit loss accounting standard, which starts taking effect for credit unions in fiscal years beginning after Dec. 15, 2020. Accessing the study requires you to provide your contact information, … Read More

DCU Bulletin B-17-07 Assets in the Process of Liquidation

The Division of Credit Union published Bulletin B-17-07 regarding the reporting of assets in the process of liquidation.  The Bulletin is reprinted below.  Please refer to the original link for footnotes. Assets in the Process of Liquidation The purpose of this bulletin is to set guidelines for how examiners will evaluate assets in the process of liquidation during examinations. Specifically, … Read More

Foreclosure Fairness Act – 2017 Requirements

It’s that time again… Homeowners that the credit union has provided a Notice of Default to, and lived in their home when the foreclosure processes started, are eligible to participate in Washington State’s Foreclosure Fairness Act Mediation Program, unless the credit union has conducted less than 50 foreclosure sales during the previous year, and claimed their exemption status to the Department … 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

Current Expected Credit Losses

On June 16, the Financial Accounting Standards Board (FASB) issued its final standard on credit losses; the Current Expected Credit Losses (CECL) model.  The standard follows a Life of Loan Concept that allows financial institutions to leverage its current internal credit risk systems as a framework for estimating expected credit losses.  The standard requires organizations to measure all expected credit … 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

SCRA Foreclosure Protection Relapses to 90 days – UPDATED

UPDATED On March 31, President Obama signed into law the “Foreclosure Relief and Extension of Servicemembers Act of 2015,” extending the sunset date to December 31, 2017.  Credit union’s SCRA Notices should (again) reflect one-year, rather than 90 days.   The Service Members Civil Relief Act provides protection for service members from foreclosure for a period of time after the end … Read More

DCU Interpretive Letter I-15-04 Complying with GAAP in Relation to MBLs

The Division of Credit Unions has published Interpretive Letter I-15-04 (Complying with GAAP in Relation to MBLs). This Interpretive Letter clarifies the requirements for Washington State-chartered credit unions when complying with generally accepted accounting principles (“GAAP”) in relation to member business loans (“MBL”) and reserving for their allowance for loan and lease losses (“ALLL”) account. From the letter, State Credit … Read More

In-Person Collection of Consumer Debt

CFPB Compliance Bulletin 2015-07 Compliance Bulletin 2015-07 warns creditors, debt buyers, and third-party collectors of potentially unlawful in-person debt collection practices.  The bulletin reminds the financial services industry of debt collection practices prohibited by the Dodd-Frank Act and the Fair Debt Collection Practices Act, including: Engaging in unfair, deceptive, or abusive acts or practices, Communicating with a consumer at any … Read More