Compliance Center: New CUNA Tools to Help Credit Unions With TILA/RESPA Compliance

In preparation for the upcoming TILA/RESPA Integrated Disclosure final rules effective August 1, 2015, CUNA has provided an excellent link on its website to compliance checklists, podcasts and other valuable resources:

Other available resources include:  

Compliance Question of the Week

When opening an account for a minor, how does the credit union verify their identity?

If the minor themselves open the account, you can verify their ID using documentary methods such as a state issued ID card, driver’s license, or work permit.  If these are not available, you can use non-documentary methods such as verification by an existing member or using public databases. If you have an adult opening an account for a minor, you must verify the ID of the adult, not the minor.  Either way, your BSA and CIP policy must specify what types of identification you will accept and under what circumstances.

This Week’s Legal Briefs

National Credit Union Administration (NCUA) 

NCUA Chairman Matz released a statement regarding the released of the Financial Stability Oversight Council’s 2015 Annual Report. In her statement, Matz stated that the Council recommends granting examination and enforcement powers over third-party service providers to the NCUA, along with recommending that financial institutions read the report and focus on the statements made on cybersecurity, interest-rate risk, and asset-liability management.

The NCUA released the May issue of the NCUA Report.

The NCUA has issued its Board Action Bulletin detailing the events of its May 21, 2015 Board Meeting. 

Consumer Financial Protection Bureau (CFPB)

The CFPB announced that it will be launching a financial coaching initiative. The coaching will be provided at locations around the country and will boast free one-on-one coaching to help consumers craft personalized financial plans.

The CFPB issued a consumer advisory, advising consumers to fact check their credit reports.

U.S. Department of the Treasury (Treasury)

The Treasury released the Fifth Annual Report of the Financial Stability Oversight Council. The report lists eleven themes that the Council feels warrant continued attention and potentially further action from the Council’s members.  

Federal Housing Finance Agency (FHFA)

Fannie Mae and Freddie Mac issued new eligibility requirements for sellers/servicers. The new requirements are both operational and financial, with the requirements becoming effective on September 1 and December 31, 2015, respectively.

Federal Reserve Board (FRB)

The FRB released Supervisory Guidance for Implementation of the Simplified Supervisory Formula Approach for Securitization Exposures under the Advanced Approaches Risk-Based Capital Rule.

The FRB announced a change in process for handing items drawn on retired routing numbers. Beginning the third quarter of 2015, the Reserve Banks will return items drawn on retired RTNs directly to the bank of first deposit.

The FRB published an FAQ about Regulation II (Debit Card Interchange Fees and Routing). The FAQs are issued to illustrate how certain provisions of the regulation apply to specific situations. However, the FRB notes that the FAQs are not official interpretations of the Board and can be revised as the FRB deems appropriate. 

The meeting minutes and statement from the April 2015 Federal Open Market Committee meeting have been released. 

Financial Crimes Enforcement Network (FinCEN)

FinCEN has announced that it has created another way to file FBAR reports, for those that must file. Filers can file using the standard PDF or the new online form.

FinCEN announced that it held its first awards ceremony to recognize law enforcement agencies using BSA data effectively to obtain successful prosecution.

Federal Housing Finance Agency (FHFA)

FHFA Director Watt delivered prepared remarks at the 2015 Federal Home Loan Banks Directors Conference. Watt’s remarks focuses on recent results and activities of the FHFA, the FHFA’s role in the banking system, and areas of focus for the FHL Banks.

The FHFA released an Update on the Structure of the Single Security.  This release is an update on the 2014 Strategic Plan for the Conservatorships of Fannie Mae and Freddie Mac that discussed the goal of developing a single mortgage-backed security Fannie Mae and Freddie Mac could issue.

Federal Reserve Board (FRB)

The FRB has published the Federal Open Market Committee’s tentative 2016 meeting schedule.

The FRB issued a Report to Congress on the Use of ACH System and Other Payment Mechanisms for Remittance Transfers to Foreign Countries.

The May edition of FedFlash is now available.

Office of Foreign Assets Control (OFAC)

OFAC has updated the SDN list as of May 21, 2015. The last update prior to this was April 28, 2015. 

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

Posted in Compliance, Federal, NCUA.