The Consumer Financial Protection Bureau (CFPB) published its asset- size exemption threshold for 2012 Home Mortgage Disclosure Act (HMDA) collection and reporting on February 15, 2012. This created an issue for credit unions which were near the threshold. The majority of these credit unions elected to collect HMDA data beginning January 1st, to ensure the information was available should they be required to report the data. Heading into 2013, credit unions will not have such an issue, as the CFPB published the 2013 threshold on December 31, 2012.
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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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While it may seem as though the Consumer Financial Protection Bureau (CFPB) has only been busy writing regulation as of late, they have also been putting out useful information for financial institutions. The CFPB has recently released some helpful information on the Remittance Transfer Rule. On Monday, October 15th, they released a “Small Business Compliance Guide” which provides an easy-to-use summary of its pending remittance transfer rule and highlights any issues that businesses might find helpful to consider when implementing the rule.
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The new TILA/RESPA and mortgage servicing rules interrupted my previously planned summer beach reading – the CFPB Examination Manual – so I was just recently getting back to it. While perusing the Manual on the beautiful bucolic beaches of Iowa, I noticed that there are a few helpful flowcharts embedded in the 800+ pages. I tried to extract the flowcharts into one document I could link to from this post, but the PDF available online from the CFPB is locked up tight to editing of any kind. So, here is the link to the Manual, and here are the page numbers along with a description of the charts:
- Page 226 – Coverage Considerations Under Reg Z (Does Reg Z Apply?)
- Page 230 – Finance Charge Chart (What is, and is not, included in the definition of finance charge?)
- Page 247 – Closed End Credit: Finance Charge Accuracy Tolerances
- Page 248 – Closed End Credit: Accuracy and Reimbursement Tolerances for Understated Finance Charges
- Page 249 – Closed End Credit: Accuracy Tolerances for Overstated Finance Charges
- Page 250 – Closed End Credit: Accuracy Tolerances for Overstated APRs
- Page 251 – Closed End Credit: Accuracy and Reimbursement Tolerances for Understated APRs
- Page 701 – Decision Tree: Privacy Notice and Opt-Out
- Page 702 – Decision Tree: Reuse & Redisclosure of Nonpublic Personal Information Received From Nonaffiliated Financial Institutions
- Page 703 – Decision Tree: Account Number Sharing
Many of these flowcharts refer to specific modules within the Examination Manual for further information. If these are issues you deal with on a regular basis, it may be worth printing these out along with any accompanying modules or descriptive pages.
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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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Are you helping members sign up for online banking? You may think this is an odd question, but if you are helping members, you may be breaking the law!
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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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