A Look Back at Compliance Issues in 2013
December 26, 2013
Dec. 26, 2013
Without a doubt, 2013 may have been one of most challenging years ever for dealing with new compliance requirements.
The New Year started out with a bang as the Consumer Financial Protection Bureau released the final rules that implemented a number of the mortgage rule changes required by the Dodd-Frank Act. Work on implementing these final rules set the tone for the year, since the entire mortgage process is being changed.
In addition, credit unions needed to ensure that their credit card applications and account-opening disclosures included a reference to the CFPB instead of to the FRB.
And finally, FFIEC issued a proposed guidance on the use of social media.
The remittance transfer rule was originally slated to be effective in February, but was moved back to October so that the CFPB could issue updated guidance.
Oregon state-chartered credit unions saw some relief from the DCBS with new rules for holding unimproved real property for future expansions.
March saw the end of U.S. Treasury benefit payments being issued by physical check. The Treasury mandated that all future payments had to be issued in electronic form.
In addition, FinCEN required all financial institutions to start using the new online forms by the end of March.
In April, the CFPB published a final rule revising the remittance transfer rule requirements and establishing a new October effective date.
A compliance break? There were no new developments in May.
The first two mortgage rule requirements became effective in June. These were changes to HPML escrow requirements and the prohibition on mandatory arbitration agreements in mortgage contracts.
In addition, the NCUA issued its final rule on loan participations in June.
July saw both proposed and final amendments to the mortgage rules that the CFPB had originally published in January.
Due to changes to the Oregon Foreclosure Avoidance Mediation Program (FAMP) passed by the Legislature, credit unions needed to recertify their exemptions from FAMP.
The CFPB released additional amendments to the mortgage rules, and the NCUA loan-participation rule took effect in September.
The remittance transfer rule finally went into effect.
Also, the CFPB released amendments to the mortgage servicing rules, and the NCUA released its final rule for liquidity and contingency funding plans.
The CFPB released the Integrated TILA/RESPA disclosure rule in November.
The NCUA published updates to its CUSO requirements, the CFPB released amendments to the exceptions to the HPMP appraisal rule, and FFIEC released the final guidance for the use of social media.
January will be a relief for many credit unions. All the work to implement the CFPB mortgage rules will be nearing completion. Rules for Mortgage Ability to Repay, changes to HOEPA, a prohibition on financing credit insurance premiums, MLO compensation changes, mortgage servicing, HPML and Reg B appraisals will all become effective in January 2014.
Questions? Contact the Compliance Hotline: 1.800.546.4465, firstname.lastname@example.org.