You may have read a few of my blog posts in the past few months updating you on the ongoing work of the Consumer Financial Protection Bureau (CFPB). A very big, recent update has been the appointment of a director for the CFPB. On Wednesday, January 4th, President Obama used a recess appointment to appoint Richard Cordray as the first director of the CFPB.
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The advice “an ounce of prevention is worth a pound of cure” used by Benjamin Franklin in the 1700s to explain the need for fire prevention may be more helpful now in this new age of regulations. While fires caused economic hardship, so can improper regulatory policies.
In order to help credit unions prevent regulatory mishaps, PolicyWorks released its first quarterly update to PolicyAid, its online policy manual for credit unions. PolicyWorks updates and amends policies on a quarterly basis based on new regulations, Letters to Credit Unions, AIRES questionnaires and best practices.
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Just in time for the holidays, the CFPB is pulling out its wrapping paper and tape and presenting the credit union community with refurbished regulations. They may look like the old regulations but they have shiny new citations.
Title X of the Dodd-Frank Act transferred rulemaking authority for numerous regulations to the CFPB on July 21, 2011. The CFPB is now in the process of republishing the transferred regulations and implementing those laws with technical changes. Last Friday it was Regulation F, I, and N. This week its C, G, H, M, B, V, J, K, L, P, and X. Each regulation is effective December 30, 2011.
No substantive changes to the regulations are expected as they are published; but who knows what we will unwrap in the next few weeks!
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If you conduct the BSA training in your credit union and you haven’t heard about Frank Mendoza, you must read this post.
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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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The Consumer Financial Protection Bureau (CFPB) has been very busy the past few months. They have released documention and information on initial mortgage disclosures and student loan disclosures through the “Know Before You Owe” initiative. Now, the CFPB has announced that they have created two new mortgage closing disclosures required by Regulation Z (Truth-in-Lending) and the Real Estate Settlement Procedures Act (RESPA).
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For the first time in some while, I am going to blog about something other than recent or upcoming changes. Relieved? Based on what I have seen in credit unions, you shouldn’t be! There just so happens to be a nondescript paragraph within the Official Staff Interpretations of Regulation B that seems to frequently get overlooked by credit unions (and banks for that matter).
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