Compliance Center: Safe Harbor Obtained!

Forty-seven attendees representing 21 different Northwest credit unions participated in CUNA’s Mortgage Loan Originator Training Course hosted by the Northwest Credit Union Association.

Last week, groups of credit union employees in Tigard, Oregon and Seatac, Washington took part in CUNA’s Mortgage Loan Originator Training Course. The training was developed by CUNA and is approved by the NMLS, which allows the training to provide a safe harbor under Regulation Z to all participants.

The training includes a jam-packed day of consumer lending regulations including requirements under the Truth in Lending Act and Real Estate Settlement Procedure Act, as well as fair lending laws. In addition to the training, participants were able to obtain a certification by taking a test based on the information shared during the course. 

The instructor for this course, Michael Christians, Compliance Attorney with PolicyWorks, led the group through seven different laws and regulations, as well as additional information on non-traditional mortgage products and additional mortgage-related requirements. Christians drove the information home by sharing real-life examples of compliance gone wrong as well as demonstrating examples of how these regulations apply in the real world. 

Christians also covered the new TILA/RESPA Integrated Disclosures and answered questions and concerns about the new requirements. He gave an overview of the CFPB’s expected HMDA changes and shared great resources that participants can use to better understand compliance requirements, as well as tools that are available to help consumers better understand the mortgage products they are applying for.

The attendees of the events had positive things to say about the training and the instructor. Callie Gibbs, Lending Services Supervisor for USAgencies Credit Union, said “Michael was clear and easy to understand. He even made compliance fun! I walked away feeling much more confident in my overall understanding of mortgage lending.”

Overall, 47 attendees representing 21 different Northwest credit unions participated in this valuable training.

Compliance Question of the Week

What are red flags for currency exchanges and other currency transactions?

This article lists various transactions and activities that may indicate potential money laundering. While not all-inclusive, the list does reflect ways that launderers have been known to operate. Transactions or activities listed here may not necessarily be indicative of money laundering if they are consistent with a customer’s legitimate business. Also, many of the “red flags” involve more than one type of transaction.

1. Unusual exchange of denominations.

An individual or group seeks the exchange of small denomination bills (five, ten and twenty dollar bills) for large denomination bills (hundred dollar bills), without any apparent legitimate business reason.

2. Check cashing companies.

Large increases in the number and/or amount of cash transactions for check cashing companies.

3. Unusual exchange by a check cashing service.

No exchange or cash-back for checks deposited by an individual who owns a check cashing service can indicate another source of cash.

4. Suspicious movement of funds.

Suspicious movement of funds out of one bank, into another bank, and bank into the first bank can be indicative of money laundering.

Related Links:

FFIEC Red Flags

Legal Briefs

National Credit Union Administration (NCUA)

The NCUA released its August Issue of the NCUA Report. The Report highlights the FFIEC Cybersecurity Assessment Tool and the Fixed-Asset Rule for federal credit unions.

The NCUA released a statement discussing its consulting services, which is slated to help 191 credit unions improve their operations and member services during the second half of 2015. The NCUA offers this program through their Office of Small Credit Union Initiatives.

Consumer Financial Protection Bureau (CFPB)

The CFPB announced that it is creating tailored state guides to help consumers and their caregivers understand how to manage someone else’s money. The CFPB has already made the state-specific tool available for Virginia and plans to create a state specific tool for five other states, including Arizona, Florida, Georgia, Illinois, and Oregon.

The CFPB released resources specifically for real estate professionals to help them better understand and explain the new TILA/RESPA disclosures to their clients.

Federal Reserve Board (FRB)

The FRB released the minutes from the July 28-29, 2015 Federal Open Market Committee.

Federal Housing Finance Agency (FHFA)

The FHFA announced that it adopted a final rule on 2015-2017 Housing Goals for Fannie Mae and Freddie Mac. The final rule includes goals for single and multi-family housing.

Office of Foreign Assets Control (OFAC)

OFAC has updated the SDN list as of August 19, 2015. The last update prior to this was August 5, 2015.

Questions? Contact the Compliance Hotline: 1.800.546.4465,

Posted in Compliance News, NCUA.