DCU Going to Electronic Consumer Complaint Communication

The Washington State Department of Financial Institutions Division of Credit Unions released Bulletin B-16-10 regarding Consumer Complaints – Electronic Communications.

The DCU will be transitioning to receiving and sending all consumer complaint communications electronically as a more efficient process.  The DCU will begin sending all consumer complaints electronically to the applicable credit union as of October 1, 2016.

Starting in October, the Division will notify the credit union of the filed complaint through encrypted email with a read receipt upon delivery. The email will be delivered to the President/CEO of the credit union, unless the credit union designates a different primary contact. The Division is also asking for every credit union to provide a second and/or third contact person, who will be cc’d on the email.

Please submit your preferred contacts by Thursday, September 15, 2016 to Allyson Ross at Allyson.ross@dfi.wa.gov.

After the credit union completes its investigation, they will need to send their response email to DCU@DFI.WA.GOV and send a copy of the response to the member.

Compliance Question of the Week

We have a member asking if it is permissible for them to store cash in their safe deposit box. We thought there was a rule against this but cannot locate one. Is it permissible for a member to keep cash in their safe deposit box?

There are no regulations which prohibit the deposit of cash in a safe deposit box. In fact, the credit union should not attempt to monitor what member place in their safe deposit boxes, other than to alert members to the types of objects which must not be placed in boxes such as explosives, toxic materials, or other items restricted per the terms of the contract.
The credit union’s duty is to exercise due care and ensure that only the member or their duly authorized agent has access to the safe deposit box.

Legal Briefs

National Credit Union Administration (NCUA)

The NCUA released the August issue of the NCUA Report.

The NCUA announced that it is streamlining the CDFI application process.

Consumer Protection Financial Bureau (CFPB)

The CFPB posted a viewed overview of the HMDA final rule on its HMDA rule implementation page.

The CFPB announced the release of a report that details the complaints of servicing problems that consumers have regarding lowering their student loan payments.

The CFPB announced the appointment of new advisory board and council members.

Federal Reserve Board (FRB)

The FRB and U.S. Mint issued an annual report to Congress as required per the program. The Federal Reserve fulfills demand for financial institutions while the Mint fulfills collector demands through direct sales.

The FRB, in conjunction with the other federal financial regulatory agencies, issued a report to Congress on the effect of capital rules on mortgage services assets.

The August edition of FedFlash is now available.

The FRB announced the update of Operating Circular 4, which updates the ACH items to reflect Phase 1 of the Same Day ACH implementation.

The FRB released the minutes from its most recent Federal Open Market Committee meeting.

The FRB updated its FAQ on its economic goals and its monetary policy.

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

HUD released the July 2016 statistics for new residential construction.

Financial Action Task Force (FATF)

The FATF issued a report of its 2016 Counter-Terrorist Financing Summit.

Federal Deposit Insurance Corporation (FDIC)

The FDIC announced that it has updated its technical assistance videos focusing on the Ability-to-Repay and Qualified Mortgage rules.

The FDIC, FRB, and OCC announced that the 2015 small business, small farm, and community development lending data is now available.

Office of Foreign Assets Control (OFAC)

OFAC has updated the SDN list as of August 16, 2016. The last update prior to this was August 15, 2016.

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

Posted in Compliance News, Federal, NWCUA.