Legal Briefs

Your update on the regulatory landscape.

Federal Reserve Board
The Fed released proposed rules that would create new protections for consumers who send remittance transfers to recipients located in a foreign country. The proposed rule is pursuant to the Dodd-Frank Act and would require certain new disclosures. Comments are due 60 days after the proposal is published in the Federal Register. Approximately July 13, 2011.

NCUA
The agency issued legal opinion letter 11-0358. The letter discusses whether or not a federal credit union may sell loans of its members to a registered mutual fund. 

Office of Foreign Assets Control
The OFAC SDN list was updated again. Last update May 17, 2011. 

FASB
The FASB and IASB issue common fair value measurement and disclosure requirements. For US GAAP, the update 2011-04 will supersede most of the guidance in Topic 820. 

Social Security Administration
The SSA Board of Trustees released its annual report on the financial health of the Social Security Trust Funds. The Trust Funds are projected to be exhausted in 2036, which is one year sooner than what had projected last year. 

OCC
The OCC released Alert 2011-5. The alert warns of a fraudulent correspondence attributed to the OCC with regard to an outstanding payment transaction. 

CFPB
The CFPB announced an initiative to combine mortgage loan disclosures. The “Know Before You Owe” project will conduct testing and select a single draft disclosure. Testing should be complete by September 2011.

US Treasury
The US Treasury department released an updated FAQ with regards to the garnishment of accounts containing federal benefit payments. One of the important clarifications is the Treasury garnishment rules only apply to court ordered garnishments. This would exempt out IRS levies, state revenue levies, and other non-court ordered attachments.

NACHA
The NACHA released a warning regarding fraudulent emails appearing to come from NACHA. NACHA has been the target of a sustained campaign of phishing attacks. NACHA itself does not process nor touch ACH transactions.

 

Questions? Contact the Compliance Hotline: 1.800.546.4465, or email us at [email protected]