Serving Members Who are Affected by a Pandemic

Credit unions may wish to review the CDC’s latest interim guidance for businesses and employers as well as other resources.

Binder with Compliance label sitting on desk3/3/2020

With the daily news updates on Coronavirus Disease 2019 (COVID-19) many credit unions are starting to wonder what this means, especially when dealing with a member or business member who is affected by the outbreak.

We are not just talking about members who became ill, but also businesses and workers impacted by this outbreak or any other natural disaster.

The National Credit Union Administration has provided guidance in the past on steps credit unions can take in order to assist members who are experiencing financial hardships due to a disaster. In addition, the Letter to Credit Unions 11-CU-05 provided guidance on planning and preparedness for a potential government shutdown. This guidance was especially helpful for credit unions assisting members during the government shutdown in late 2018 and into 2019. Members working for import or export companies may also be facing similar hardships. The guidance suggests that credit unions:

  • Ensure policies provide flexibility to respond to members’ financial needs in the event of a federal government shutdown;
  • Prepare for service interruptions if a shutdown affects access to credit union offices and branches located in federal buildings;
  • Take steps to prudently work with members affected by a shutdown, including providing advances to individuals receiving direct deposits from the federal government;
  • Develop contingency plans for what will happen with respect to participation in government programs in the event of a shutdown. For example, some credit unions offer loans backed by the Federal Housing Administration (FHA). Individual credit unions will therefore need to decide whether to proceed with scheduled FHA loan closings and whether to hold and guarantee new FHA loans until any impasse on federal spending ends; and
  • Communicate response plans and efforts before, during, and after any shutdown to keep members, volunteers, and employees informed.

Credit unions may wish to ensure they have a plan to offer individualized financial solutions to their members facing financial hardship in any crisis or disaster.

As employers, credit unions may wish to review the latest Interim Guidance for Businesses and Employers that the Centers for Disease Control and Prevention has issued.

In addition, the guidance from the Equal Employment Opportunity Commission does state that during a pandemic, employers may advise an employee to go home if they show symptoms of influenza-like illness.

Question of the Week

Q. We suspect that an individual has brought in a fraudulent check from the U.S. Treasury. Is there a way we can verify the legitimacy of the check? 

A. Yes. The Treasury has a website that enables financial institutions to verify the check online. In addition to the verification website, the Treasury has a guide that explains the security features that should be visible on the check.

Resources

Treasury Check Information System

U.S. Treasury Check Security Features

Legal Briefs

National Credit Union Administration

Financial Inclusion Webinar

The NCUA will host a webinar on March 11 to provide insights into serving low-income and underserved communities.

Consumer Financial Protection Bureau

TRID FAQs

The CFPB released a set of questions and answers that pertain to the TILA-RESPA Integrated Disclosure Rule (TRID), which cover topics such as correcting closing disclosures, model forms, construction loans, providing loan estimates to consumers, and lender credits.

COVID-19 Resources

NWCUA’s compliance article for the week of Feb. 11 provided an extensive list of recommendations by regulators and resource links.

Oregon Health Authority COVID-19 Page Guide

Washington State Department of Health 2019 “Novel Coronavirus Outbreak” Page

Idaho Department of Health and Welfare Novel Coronavirus Page

Centers for Disease Control and Prevention Coronavirus Disease 2019 Page

Additional CDC Communications Resources:

Fact Sheets

Buttons and Badges

Videos

What’s New?

Office of Foreign Assets Control

OFAC has updated the SDN list as of March 2. The last update prior to this was Feb. 20.

­­­­­­­­­­­­­­­­­­­Questions? Contact the Compliance Hotline: 1.800.546.4465; [email protected].