Legal Briefs

Consumer Financial Protection Bureau (CFPB)

The CFPB has published a request for comment on effective financial education approaches. The CFPB is hoping to gather information on consumer financial education and what works. Comments are due by Oct. 31, 2012.

The CFPB issued proposed guidelines designed to protect the Bureau’s information sharing. The guidelines detail the Bureau’s administrative mechanisms to allow affected persons to seek and obtain appropriate correction of information maintained and disseminated by the Bureau that does not comply with the Office of Management and Budget or the Bureau guidelines. Comments are due by Sept. 4, 2012.

The CFPB is asking for input into cases that the Bureau may wish to consider filing amicus briefs on.

The CFPB has made changes to the Regulation E remittance transfer rules to make it easier for certain financial institutions to comply. The Bureau has provided a safe harbor of those institutions that consistently conduct 100 or fewer remittance transfers per year do not provide transfers in the ‘normal course of business’ and therefore are not subject to the new requirements.


National Credit Union Administration (NCUA)

The NCUA will be hosting a webinar on Aug. 14 entitled, “CLF and Your Credit Union’s Contingent Liquidity.” The webinar will discuss upcoming changes in the ownership of the CLF, the CLF’s role in meeting credit unions’ contingent liquidity needs, and issues around the proposed rule on access to emergency liquidity. Anyone wishing to attend the webinar will need to register on the NCUA’s Webinar site.

The NCUA issued Letter to Credit Unions 12-CU-10. The letter covers two concerns that may affect credit unions’ contingent liquidity plans. The first issue is the closing of U.S. Central Bridge by October 31, 2012, and the second issue is the NCUA board’s proposed rule that will require credit unions to plan for emergency liquidity.

The NCUA issued Letter to Credit Unions 12-CU-11. The letter covers Interest Rate Risk Policy and Program frequently asked questions.

The NCUA issued Letter to Federal Credit Unions 12-FCU-04. This Letter covers the NCUA Board’s decision to continue the current 18 percent interest rate ceiling for loans made by federally chartered credit unions. This rate cap does not apply to state chartered credit unions.

The NCUA announced that Agency’s initiative to streamline the process for federal credit unions to receive low-income designation. The NCUA sent letters to 1000+ federal credit unions alerting them of their LICU eligibility, and credit unions receiving the letters may not ‘opt-in’ with a simple reply instead of having to complete the required paperwork.


Office of Foreign Assets Control (OFAC)

The OFAC SDN list was updated again. Last update: Aug. 7, 2012.


The Federal Reserve Board (FRB)

The FRB has extended the deadline for borrowers seeking a review of their mortgage foreclosures under the federal banking agencies’ Independent Foreclosure Review to Dec. 31, 2012. The deadline extension provides more time to increase awareness about the Independent Foreclosure Review and how eligible borrowers may request a review.


U.S. Department of Housing and Urban Development (HUD)

The HUD has updated the expiration date of HUD-92070 Legal Rights and Protections under the SCRA. The expiration date of Nov. 30, 2014, is the only change to the form. Lenders must notify members in default of the mortgage and foreclosure rights of servicemembers and their dependents under the SCRA.


Questions? Contact the Compliance Hotline: 1.800.546.4465, compliance@nwcua.org.

Posted in Compliance, Federal, NCUA.