Compliance Gets to Breathe Easier for the Second Half of 2010

The three major regulation changes (Regs. E, Z and FACTA) that went into effect today mark the turning point for the majority of the changes we will see in 2010.  While a few changes yet remain, credit unions have successfully implemented the bulk of the new requirements effective in 2010.  Congratulations!

Since the beginning of the year we have gone through 12 major changes.  These changes are: RESPA reform, new operating fees for federal credit unions, new overdraft disclosures under TIS, Student loan changes under Reg. Z, changes to credit card lending under the Credit CARD act, new escrow requirements for HOEPA loans, a new e-withhold process from the DOR, implementing the Unlawful Internet Gambling Enforcement Act, expanded provisions for the protection of vulnerable adults, debit and ATM overdraft protection changes, changes to open end lending under the Credit CARD act, and new requirements for the accuracy and integrity of information under FACTA..

You have implemented all these changes and more while dealing with some of the hardest economic conditions we have seen in our lives.  Exams are tougher, capital requirements are more rigorous, and let’s not even talk about allowance for loan and lease losses accounts. In today’s climate we talk about CAMEL ratings and jokingly say that “2 is the new 1.”

And through all of that you’ve held your heads high.  You’ve focused on serving the members.  Take a moment to breathe in deeply and let it out slowly.  Let all the stress out with your breathe.  The worst is behind us.  In comparison, the rest of 2010 will be a cake walk.  Maybe.

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