If perusing the Federal Register is not part of your daily grind (or your idea of fun) then you may have missed the CFPB’s Semiannual Regulatory Agenda and Fiscal Year 2011 Regulatory Plan published in the Register on February 13th.
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If you are like me you have a significant number of favorites set up in your web browser to assist you with your ongoing compliance responsibilities. Take for instance Regulation Z (Truth in Lending). I have Title 12 Chapter II Part 226 from the electronic Code of Federal Regulations bookmarked (no, unfortunately I don’t have it memorized).
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Everyone knows what Regulation E is but are you in compliance when it comes to your error resolution procedures? Recently, a bank in Indiana was slapped with civil money penalties of $82,500 by the FDIC for Reg E violations. So, you are probably asking yourself, what did the bank do? Well, one thing they didn’t do was follow the error resolution notice requirements.
This particular bank was requiring the customer to provide a police report on claims of unauthorized use of debit/atm cards. The error resolution protections afforded by Reg E, Section 205.11 prohibit you from requiring a member to file a police report as a condition of you providing the protections afforded by Reg E. So if are looking for an end of the year compliance project, I would suggest taking a look at your Reg E error resolution procedures to ensure you are providing your members with their rights and protections under the rule.
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Typically, we use our blog to keep you posted on compliance hot topics however with it being Thanksgiving week we thought we would share this special credit union story that was posted by the North Carolina Charlotte Observer on November 17, 2011. Enjoy your holiday and don’t forget to support our military and their families during this season of giving!
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Are you responsible for the task of policy development at your credit union but struggle with the how and where to start? PolicyWorks is excited to introduce our newest service, PolicyAid. PolicyAid is a comprehensive, online, policy library that will help your credit union develop and maintain policies as regulations change.
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There is no regulation that states you must have a succession plan, it’s simply good business practice. A succession plan is also something your regulator may ask to view and the lack of one could impact your Examination Strategic Risk Rating. So if succession planning is on your to do list then here are a few things to consider.
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Whether you are new to indirect lending or a seasoned veteran, keeping a watchful eye on this segment of your business is a must do. An improperly managed program can quickly have negative consequences on all of your risk areas from credit risk to reputation risk.
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