Compliance Center: Compliance is a Burden. We Can Help.

When surveyed, credit unions continue to site compliance as one of the top issues facing the credit union industry. This is not surprising when you consider the breadth of laws and regulations that have been introduced and amended over the past several years. These changes have affected every aspect of credit union operations; no stone has been left unturned. The next few years are shaping up to be equally challenging for the credit union industry.

Managing the onslaught of regulatory changes is a monumental task, especially while dealing with the economic downturn; trying to find new income sources; and focusing on member needs. An increasing number of credit unions are looking for technology solutions to improve their bottom line, streamline internal processes, and increase member retention.

In response to these growing credit union concerns, League InfoSight brought its newest product addition, ComplySight to credit unions in 2014. League InfoSight was founded in 2003 as part of a multi-league collaboration to provide useful compliance resources to member credit unions.

Northwest Credit Union Association credit unions continue to benefit today from this powerful cooperative association with the dues-supported suite of products such as InfoSight- the online compliance information resource; CU PolicyPro—the online policy resource; CAL—the Compliance Answer Library that is a searchable FAQ database of compliance questions and answers; and the Compliance Hotline—which allows credit unions to get assistance from our staff compliance experts

Would you like to get email notifications when regulations change? Small to large credit unions across 31 different states do—and that’s just one of the benefits. See for yourself with a free, 30-day trial of ComplySight.

ComplySight provides visibility, tracking, measuring and reporting for compliance activities through a single application. It is an affordable solution that:

  • Notifies users when regulations are finalized.
  • Assists in tracking Examiner and Audit findings.
  • Provides a summary of applicable regulations to test against existing policies, practices and procedures.

Compliance doesn’t have to be overwhelming and this is a great opportunity to make things easier on yourself. Here’s a quote from one of many happy users:

“ComplySight is a fantastic product that should be in every compliance officer’s toolbox. Not only can it be used to keep current on changing regulations, but it can also be used for quick access to a wide range of resources on a multitude of compliance topics. It is the first place I turn when I need a sample policy or have a compliance related question.”

The Northwest Credit Union Association is offering a free, 30-day trial of ComplySight to our member credit unions so you can see the benefits first hand. It’s easy to get started. Just send an inquiry to compliance@nwcua.org

Compliance Question of the Week

Can the credit union require a borrower who has a less than stellar credit history to triple the amount of money that goes into their escrow account?   

Section 17 of RESPA sets limits on the amounts that a lender may require a borrower to put into an escrow account for purposes of paying taxes, hazard insurance, and other charges related to the property.

During the course of the loan, RESPA prohibits a lender from charging excessive amounts for the escrow account.  Each month the lender may require a borrower to pay into the escrow account no more than 1/12 of the total of all disbursements payable during the year, plus an amount necessary to pay for any shortage in the account.  In addition, the lender may require a cushion, not to exceed an amount equal to 1/6 of the total disbursements for the year.

The lender must perform an escrow account analysis once during the year and notify the borrower of any shortage.  Any excess of $50 or more must be returned to the borrower.

Related Links:

12 CFR 1024.17

Legal Briefs

National Credit Union Administration (NCUA)

The NCUA released the video recording of its June 2016 meeting.

NCUA Chairman Metsger discussed the importance of CDFI Certifications and how they help credit unions better serve their members and their community during a speech at CUNA’s America’s Credit Union Conference.

Consumer Financial Protection Bureau (CFPB)

CFPB Director Cordray delivered prepared remarks at the Financial Literacy and Education Commission Meeting.

The CFPB’s monthly complaint snapshot was released. This month’s snapshot focuses on complaints about consumer loans including vehicle loans and leases, installment loans, title loans, and pawn loans.

The CFPB issued a proposed rule that would implement the amendments made via the December 2015 statutory changes to Regulation P. The proposed rule would implement the exception to the annual privacy notice requirement if certain conditions are met by the financial institution.

Federal Reserve Board (FRB)

The FRB announced that the schedule for the 2017 Federal Open Market Committee meetings is now available.

The FRB released a reports of commercial banks that have consolidated assets of $300 million or more.

The FRB released its June 2016 Senior Credit Officer Opinion Survey on Dealer Financing Terms.

Federal Housing Finance Agency (FHFA)

The FHFA announced that its data shows a national decrease in mortgage rates on conventional purchase-money mortgages.

The FHFA released details on the process of the Fannie Mae and Freddie Mac Credit Risk Transfer Programs.

The Office of the Comptroller of the Currency (OCC)

OCC Comptroller Curry discussed efforts to promote community revitalization through innovative funding and other assistance to support rehabilitation of homes in distressed communities.

Federal Deposit Insurance Corporation (FDIC)

The FDIC announced the launch of a survey of banks regarding their small business lending practices. The survey is aimed at providing new information on banks’ market areas for small business lending and perceived competition.

The FDIC issued guidance on frequently asked questions on identifying, accepting, and reporting brokered deposits.

US Department of Housing and Urban Development (HUD)

HUD published early findings on a study it conducted on the benefits that housing education and counseling provides to first-time homebuyers.

Federal Financial Institutions Examination Council (FFIEC)

The FFIEC has updated its Geocoding system to reflect 2016 data.

Office of Foreign Assets Control (OFAC)

OFAC has updated the SDN list as of June 30, 2016. The last update prior to this was June 23, 2016.

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

Posted in Compliance News, Federal, NWCUA.