Back on January 8th, the Consumer Financial Protection Bureau (CFPB) published its Semiannual Regulatory Agenda.
Much of its expected rule-making has since hit the World Wide Web, and PolicyWorks is reading and dissecting thousands of pages of regulation to provide you with the nuts and bolts of the rules. While others may read books, magazines or their favorite website; we read regulations. And, to some extent; we enjoy it. We’re weird like that.
Thus far in 2013, the CFPB has issued final rules related to High Cost Mortgages and Homeownership Counseling, Escrow, the Ability to Repay and Qualified Mortgage Standards, Mortgage Servicing, Disclosure and Delivery of Appraisals, Appraisals for Higher Priced Mortgage loans, and Loan Originator Compensation. They have also issued proposed revisions to the delayed Remittance Transfer rule. If their New Year’s resolution was to keep us busy, I would consider this a success.
While most New Year’s resolutions don’t last beyond the first month, the CFPB expects to see this one through. A final rule amending Regulation CC and Expedited Funds Availability is expected in August. And, perhaps the most momentous of all- the rule combining RESPA and Truth in Lending disclosures- is expected in September of this year.
These are definitely busy times in regulatory compliance, and it doesn’t appear to be slowing any time soon. (It seems as though we say that a lot, but, it continues to be true.) Be sure to keep your eye on The Works Blog, and the CFPB Regulations page for additional rules and guidance. There will be no shortage of information forthcoming in the next 12 months!
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As the Director of Regulatory Compliance here at PolicyWorks, my primary function is to lead the delivery of our compliance review services. I enjoy getting out of the office and working onsite with our credit union clients to help them identify, and correct, compliance deficiencies. In addition to the pleasure of working side-by-side with our credit union partners, this onsite work allows me to witness the practical implementation of regulations. I have learned that there are, often, multiple good ways of implementing compliance. I have also learned that there are errors which are common among credit unions and which are, usually, easily corrected. From time to time, I’ll use this blog to relay tips, tricks, and other good practices that I observe. I’ll also alert you to common mistakes that you can check for in your own credit union.
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When I visit credit unions, I am frequently asked to review branch signage and posted disclosures. As you may recall, I previously blogged about the HMDA Notice requirement in May. Another required notice that credit unions seem to have difficulty posting properly is the Regulation CC (Funds Availability) lobby notice.
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As more and more credit unions turn to social media sites such as Facebook, Twitter, Foursquare, and Pinterest (just to name a few) to promote their products and services, most seem to be overlooking the little detail that they are actually engaging in advertising which is heavily regulated.
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You may have already known that credit unions are required to post the NCUA Official Advertising Statement on its main internet page. But did you know that if the credit union accepts deposits or allows for the opening of accounts on its internet page, the requirements are different? Based on the websites that I have seen, most credit unions are not aware of the differences…so lets review the requirements!
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When the new final remittance rule was released by the CFPB, many of you probably assumed it didn’t apply to your credit union because you don’t do traditional remittance transfers. Well, if you do international wire transfers or international ACH transactions, it may apply to you.
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This week I am teaching a session at PayFusion’s Debit Card School in Boston about Reg E and debit card compliance issues. I thought I would share with you some of what will be discussed at the school. I also raise the issue here because recently the NCUA’s consumer compliance area indicated that some of the most common complaints they get are related to unauthorized transactions and Reg E.
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