If you remember last summer, NCUA’s Office of Consumer Protection notified over 1000 federal credit unions across the country of their eligibility for low income designation. NCUA’s initiative was in part due to President Obama’s relief and recovery package to help drought stricken states across the country. Many of you accepted the designation; however, do you truly understand the grant opportunities available as a low income designated credit union?
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Last week we released our quarterly update to PolicyAid, our online policy solution. We included a new Fair Lending Policy to assist both federal and state chartered credit unions with their fair lending program. This new policy was developed in light of NCUA’s recently published Fair Lending Guide. In addition, we’ve updated a few of our existing policies based on final rules. Our April updates include the following:
- Fair Lending Policy (New)
- Electronic Funds Transfer Policy (Updated)
- Investment Policy (Updated)
- Servicemembers Civil Relief Act and Permanent Change of Station Policy (Updated)
- Real Estate Lending Policy (Updated)
If you aren’t already a subscriber…. check us out. We offer an annual subscription to a library of over 70 policies and counting for a mere $299. If you are tired of spending countless hours just staring at a blank piece of paper trying to get started, subscribe today and let us help you save time and energy. Our policies are in word document format and can easily be downloaded and customized to fit your credit union’s needs. For questions please contact us at policyadmin@policyworksllc.com or 1-855-341-4643.
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As of October 1, 2012, each federally insured credit union had to adopt written policies addressing loan workouts. A credit unions loan workout policy and practices should be commensurate with the credit union’s size and complexity and coincide with the credit union’s risk mitigation strategies. Seems simple enough; however, questions were still lingering for both the credit unions and the Examiners on this new rule.
After soliciting feedback from credit union officials and accounting professionals, NCUA prepared and released new loan workout, nonaccrual and TDR guidance for the Examiners to follow (Letter 13-CU-03). Although this guidance is directed at field staff, it provides credit unions with valuable insight on what to expect when your Examiner inquires about your loan workout policies and procedures.
If you haven’t had a chance to review the letter yet, I would strongly encourage you to take some time in the coming days to review to ensure your loan workout program will meet examiner expectations. A little due diligence now can save you time later dealing with unwanted Examiner Finding or Document of Resolution items related to this area.
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NCUA recently created and released a new Fair Lending Guide. The guide was included in Letter to Federal Credit Unions, 13-FCU-12; however, state chartered credit unions can definitely take advantage of the guide as well.
NCUA supervises and enforces fair lending laws and regulations at federal credit unions and is also in a position to educate federally insured credit unions on their fair lending and consumer protection obligations. Fair lending laws and regulations encompass:
- Equal Credit Opportunity Act (Regulation B);
- Home Mortgage Disclosure Act (Regulation C); and
- Fair Housing Act (FHA).
Although NCUA does not actually issue these regulations, the laws require NCUA to enforce these regulations in the process of supervising federal credit unions.
In addition to the Fair Lending Guide, NCUA is also hosting a free webinar entitled, “Fair Lending Examination Program and Compliance Assistance” on Thursday, April 4, 2013 at 1 pm eastern. During the session NCUA’s Office of Consumer Protection staff will discuss NCUA’s ongoing fair lending program, including:
- An overview of NCUA’s fair lending examination program, including off-site supervision contacts;
- Fair lending best practices credit unions should consider; and
- The new Fair Lending Guide
So if you and your staff need a refresher on complying with fair lending laws I strongly encourage you to take advantage of these free NCUA resources.
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Tuesday, February 19th was the effective date of NCUA’s final rule amending the definition of small entity from credit unions with less than $10 million in assets to less than $50 million in assets. So if you haven’t had a chance to read this rule because you are overworked and overstressed reading the CFPB’s mortgage rules let me give you a high level overview of the three key areas you need to know.
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January 27, 2013, seemed like just another winter day but there were actually some significant changes that took effect on Sunday that will impact consumers and their pocket books.
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I hope you all enjoyed the holidays. I am sure many of you are trying to slowly get back into the swing of things. So I thought I would take this opportunity to gently nudge you back into compliance by giving you a simple homework assignment. Take a field trip of your branches and review your Adverse Action, Risk Based Pricing Notices and your Credit Card tabular forms to ensure staff is using a compliant version. This is definitely an easy find for your Examiners in 2013 so why not avoid an Examiner Finding.
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