Website Compliance Exams

The Washington State DCU plans on restarting to conduct website compliance exams beginning mid-December.  These exams will not be performed in conjunction with regular safety and soundness examinations, nor will there be giving a separate website compliance rating.

Examiner’s concerns and findings will be included in a separate website compliance exam report. The exam report will be brief in nature and in letter form. The report letter will state the following:

  • The scope of the exam work that was performed;
  • Who performed the exam and their contact information;
  • List the concerns and findings found during the exam review, and an explanation for the concern/finding; and
  • State what must be done to correct the concerns/findings.

The credit union will receive a pre-exam notification letter in advance of an offsite website compliance examination. The pre-exam letter will not request that any documentation be prepared by the credit union. It will list general information about the exam, disclose what compliance regulations and/or guidance will be reviewed during the exam, and request a credit union contact person, if examiners have questions.

The exams will cover:

  • Accuracy of Advertising and Notice of Insured Deposit Status (12 CFR 740);
  • Equal Credit Opportunity Act (ECOA – Regulation B);
  • Fair Housing Act (FHA);
  • Children’s Online Privacy Protection Act (COPPA – NCUA Regulatory Alert 01- RA-07);
  • Electronic Funds Transfer Act (Regulation E);
  • Privacy of Consumer Financial Information Act (Regulation P and 12 CFR 716);
  • Truth in Lending Act (Regulation Z);
  • Availability of Funds and Collections of Checks (Regulation CC);
  • Truth in Saving Act (Regulation DD and 12 CFR 707);
  • Bank Secrecy Act (BSA);
  • USA Patriot Act;
  • Phishing Prevention (NCUA Letter to Credit Unions 05-CU-20);
  • Hyperlink Accuracy and Disclosure;
  • Bounce Protection Disclosures and Marketing (NCUA Letter to CUs 05-CU-03);
  • Equal Employment Opportunity Act (EEOA);
  • Electronic Signatures in Global and National Commerce Act (E-SIGN Act); and
  • Secure and Fair Enforcement for Mortgage Licensing Act of 2018 (SAFE Act – 12 CFR 761).
Passwords to access the blog posts, and blog posts are only for NWCG owners and retained clients. These should not be shared outside of the credit union. Blog posts generally contain only a summary of any requirements, and do not represent all potential impact on the credit unions. For further details on any blog post, contact NWCG or references cited in the blog post. The information contained on this site is provided for informational purposes only, and should not be construed as legal advice.

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