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).