The Mask Mandates Are Ending — Now What?

Multiple states have announced ending one of the most outwardly visible signs of the COVID-19 pandemic.

On Monday, March 21, Governor Inslee intends to lift the Washington State mask mandate for most public indoor spaces.

No later than Thursday, March 31, Governor Brown intends to also lift the Oregon mask mandate for most public spaces.

Not all public spaces will have the mask mandates lifted. Health care facilities, long-term care facilities, and correctional facilities will continue to have mask requirements.

What does this mean for credit unions?

First, while the statewide mandates are being lifted, credit unions will still need to stay informed of any specific requirements from their local health authority.

Second, businesses will have the ability to set their own policies and requirements regarding mask use after the statewide mandates are lifted.

Third, protections will remain in place for employees and consumers who wish to continue to wear masks. Credit unions may not require their employees to not wear masks if the employees choose to voluntarily wear masks.

Fourth, while the lifting of the mask mandates is a major step forward, the emergency declarations are still in place until further notice.

Question of the Week

Q. Does the credit union have to give notice prior to charging an inactive or dormant account fee?

A. Yes, under the unclaimed property statutes in Idaho, Oregon and Washington, a written notice must be sent to a member at the member’s last known address no more than three months before charging a dormant account fee.

Related Links

IDS 14-506(3)
ORS 98.308(2)(d)
RCW 63.29.060(4)(b)

Compliance Alerts

National Credit Union Administration

2022 TILA HMPL Annual Asset-Size Exemption Threshold Adjustment: The NCUA issued Regulatory Alert 22-RA-03 to remind credit unions of the annual adjustments that the CFPB made to the asset-size exemption thresholds for escrowing for higher-priced mortgage loans.

IFR on PCA Relief Renewed: The NCUA Board approved an interim final rule that would extend two temporary changes to the NCUA’s prompt corrective action regulations. he first amends these regulations to temporarily extend the Board’s ability to issue an order applicable to all federally insured credit unions to waive the earnings retention requirement for any federally insured credit union that is classified as adequately capitalized. The second extends a provision that modifies the specific documentation required for net worth restoration plans for federally insured credit unions that become undercapitalized.

Consumer Financial Protection Bureau

Compliance Bulletin on the EFTA Compulsory Use Prohibition and Government Benefit Accounts: The CFPB issued CFPB Bulletin 2022-02 to reiterate the Electronic Fund Transfer Act prohibition that stipulates that no person may require a consumer to establish an account for receipt of electronic fund transfers with a particular financial institution as a condition of receipt of a government benefit.

CFPB Launches New Way for the Public to Petition the Agency for Action: The CFPB launched a portal that will allow members of the public to submit petitions for rulemaking changes directly to the Bureau.  Members of the public can request that the Bureau pursue a new rule, amend an existing one, or repeal a rule.

Office of Foreign Assets Control

OFAC has updated the SDN list as of Feb. 17. The last update prior to this was Feb. 10.

Questions? Contact the Compliance Hotline: 1.800.546.4465;

Posted in Compliance News, Compliance News, Compliance Question.