Legal Briefs March 31, 2011

Your update of the regulatory landscape.

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Federal Reserve Board

The FRB has released final rules updating the dollar thresholds for Reg M and Reg Z. The amendment is to implement the increase of the threshold for exempt consumer credit transactions from $25,000 to $50,000.  These changes will go into effect on July 21, 2011. 

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National Credit Union Administration

The NCUA issued interagency guidance on accepting accounts from foreign embassies, consulates, and missions.  The clarified expectations confirm that credit unions have the flexibility to provide services to foreign missions while also remaining in compliance with the BSA requirements.

The NCUA issued Letter to Federal Unions 11-FCU-03. This letter and its attached enclosure cover community charter conversions and expansions.

The NCUA issued Letter to Credit Unions 11-CU-02. This letter and its attached enclosure cover changes to the NCUA 5300 call report that will be effective March 2011.  These changes include separate lines for TDRs.

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Office of Foreign Assets Control

The OFAC SDN list was updated again.  Last update March 30, 2011.

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DCBS

The Oregon DCBS released Six Myths of Flood Insurance.  In recognition of Flood Safety Awareness Week, the report covers some common misunderstandings around flood insurance.

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NMLS Registry

The NMLS has proposed a fee schedule in connection with the transfer of federally registered mortgage loan originators following a corporate merger, acquisition or merger.  The fees would be $750 for Merger and Acquisition base processing fee, and $10 for each record successfully processed.  Comments are due by April 25, 2011.

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FinCEN

The FinCEN released the 2010 Mortgage Fraud Report.  The report details that SAR filings are up and there has been a potential abuse of bankruptcy that has been identified.

The FinCEN released Commercial Real Estate Fraud Analysis and Advisory report.

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