Legal Briefs September 1, 2010
Your update of the regulatory landscape.
Federal Reserve Board
The FBR released an Inter Agency Regulation Z exam procedure. The new exam procedure includes a summary of Reg Z, including all the recent updates.
National Credit Union Administration
The NCUA has scheduled a Town Hall meeting in Portland Oregon for October 05, 2010. The Town Hall will feature presentations by senior NCUA staff regarding corporate and natural person credit unions, recent regulatory developments, and future changes necessitated by the Financial Reform Act.
The NCUA published Letter 10-CU-13 with regards to compliance deadline for the S.A.F.E. Act. The letter provides background, regulatory language, and answers to frequently asked questions.
The NCUA published Letter 10-CU-14 with regards to strengthening funding and liquidity risk management. The letter provides guidance for sound practices to manage funding and liquidity risks.
The NCUA published letter 10-CU-15 with regards to indirect lending and appropriate due diligence. The letter details the risk management practices that are appropriate and necessary to soundly manage an indirect lending program.
Office of Foreign Assets Control
The OFAC SDN list was updated again. Last update August 30, 2010.
The OCC published 2 Advanced Notices of Proposed Rulemaking. The first deals with the use of Credit Ratings in regulatory capital standards. The second deals with the use of credit ratings in other OCC regulations. Comments are due on October 25 and October 12 respectively.
The NACHA released a Healthcare and Financial Leaders Collaborative Industry White Paper on the affects of the Health Information Technology for Economic and Clinical Health Act on today’s financial institutions and their services for the healthcare sector.
The NACHA has requested comments on the proposed changes to the NACHA Operating Rules entitled “Pain Points in the Rules” The changes are to eliminate certain “pain points” in the NACHA Operating Rules that have been identified. Comments are due by September 30, 2010.