CUNA recently published a white paper in conjunction with the National Federation of Community Development Credit Unions. The white paper discusses CDFI (Community Development Financial Institution) certification, including the benefits and the process. Why should you care?
CDFI certification has numerous benefits that are outlined in the white paper. One of the major compliance benefits of CDFI certification relates to the CFPB’s Ability to Repay/QM rule: a complete exemption from the rule. Yes, you read that correctly, a blanket exemption. Even if you think you have figured out how to comply with the rule (at least I hope you have), you don’t know what your liability is or may be going forward. And, you don’t know how many times the CFPB is going to change the rule, which will require you to revise your strategy, policies, procedures, etc. I would strongly encourage you to at least read the white paper and see if you might be eligible for CDFI certification.
On another note, PolicyWorks is looking for people who love compliance as much as we do. We have two open positions–a Compliance Officer and Compliance Consultant. The catch is, you MUST love, or at least really like, compliance and helping credit unions. If you or anyone you know might be interested, you can access information about the jobs here.