Legal Briefs

The Federal Reserve Board (FRB)
released the final rules regarding the disclosure of credit scores on Risk Based Pricing Notices and Adverse Action Notices. These changes were implementing a requirement of the Dodd-Frank Act and are effective on July 21, 2011. 

The Federal Reserve Board (FRB) published lists of institutions that are subject to, and exempt from, the debit card interchange fee standards in Regulation II. The lists are intended to help payment card networks and others determine which issuers qualify for the statutory exemption from interchange fee standards. 

The NCUA released Letter to Credit Unions
11-CU-09.This letter to credit unions covers the FFIEC supplement to authentication in an internet banking environment. Federally insured credit unions will be expected to adapt appropriate strategies from the supplement to strengthen and enhance controls by January 2012. Beginning in 2012, at a credit union offering electronic services, NCUA examiners will evaluate these controls under the enhanced expectation outlined in the supplement. Credit unions that use a 3rd party to provide their online offers will still need to ensure that their provider is meeting these expectations.

Washington DCU
The Washington State Division of Credit Unions (DCU) published DCU Bulletin
B-11-04.The bulletin provides information regarding the change that will allow Washington state government and political subdivisions to deposit public funds in qualified Washington chartered credit unions. This change began on July 1, 2011.

The Bureau of Consumer Financial Protection (CFPB)
released a joint statement of principles with the Military’s Top Uniformed Lawyers. The goal of the statement of principles is to provide stronger protections for service members and their families in connection with consumer products and services.

The Bureau of Consumer Financial Protection (CFPB) released an outline of the agency’s approach to supervising large depository institutions to ensure compliance with federal consumer financial protection laws. While the CFPB will only have direct supervisory authority of the 3 largest credit unions, their examinations will set the tone for other examiners like the NCUA, DCBS, and DCU.

The Department of Housing and Urban Development (HUD) released a
final rule making technical corrects to RESPA. These changes cover clarifications on GFEs and HUD-1s and will be effective on August 10, 2011. 

US Treasury
The US Treasury announced that as of January 1, 2012, paper savings bonds will no longer be sold at financial institutions. Electronic savings bonds will still be available, but this effort will save over $70 million for the first 5 years.


Questions? Contact the Compliance Hotline: 1.800.546.4465,


Posted in Federal, NCUA.