One of the benefits of your credit union's League membership is access to InfoSight--a valuable online compliance resource. This newsletter contains some timely highlights, and access to InfoSight is a benefit of League affiliation, so it is password-protected. If you have a specific compliance issue or concern, contact our Consulting Department at (800) 285-5300. Replies to this email will be directed to SVP, League Services & Regulatory Analysis Joe Guilfoy .
InfoSight Highlight
Loan Channel – Home Mortgage Disclosure Act (HMDA)
The Home Mortgage Disclosure Act had some significant changes that were effective January 1, 2018 and this channel in InfoSight was updated to reflect those changes. Included among them were:
  • The types of transactions needing to be reported;
  • New data points to be captured and reported;
  • Collection and reporting of certain applicant information;
  • Method of data reporting; and
  • Required disclosures

Click here to view the topic , and to ensure your credit union is in compliance.
Compliance Videos
Compliance Outlook for Q4 2017
In this video, Glory LeDu provides a brief summary of the key changes of the new HMDA rules that became effective January 1, 2018. You won’t want to miss this important overview!

Just a reminder that Compliance videos since 2016 can be found on YouTube at the Compliance Connection channel , where they are generally updated quarterly.
Compliance News
Consumer Financial Protection Bureau Finalizes Changes to Prepaid Accounts Rule
The Consumer Financial Protection Bureau (Bureau) has announced that it has finalized updates to its 2016 prepaid rule. The Bureau’s 2016 prepaid rule put in place requirements for treatment of funds on lost or stolen cards, error resolution and investigation, upfront fee disclosures, access to account information and overdraft features if offered in conjunction with prepaid accounts. Recent changes announced adjust requirements for resolving errors on unregistered accounts, provide greater flexibility for credit cards linked to digital wallets, and extend the effective date of the rule by one year to April 2019 . 

Prepaid accounts are among the fastest growing consumer financial products in the United States, usually purchased at retail outlets or online. Prepaid accounts may be loaded with funds by a consumer or by a third party, such as an employer. Consumers generally can use these accounts to make payments, store funds, withdraw cash at ATMs, receive direct deposits, or send money to others. According to industry analysts, the amount consumers put on “general purpose reloadable” prepaid cards grew from less than $1 billion in 2003 to nearly $65 billion in 2012. The total dollar value loaded onto these prepaid cards is expected to nearly double to $116 billion by 2020.

The changes to the prepaid rule will:
  • Adjust error resolution requirements: In June 2017, the Bureau proposed amendments to require consumers to register their accounts to receive fraud and error protection benefits, such as the right to dispute charges and have stolen money restored, and to extend the protections retroactively to suspected thefts or disputes occurring before registration was successfully completed. Recent changes provide that the error resolution and liability limitation protections apply prospectively, after a consumer’s identity has been verified. These changes will help encourage prompt registration and streamline compliance for financial institutions as well as ensure continued availability and utility of prepaid accounts for consumers.
  • Provide more flexibility concerning credit cards linked to digital wallets: Digital wallets provide consumers with an electronic way to use their debit and credit cards. Some digital wallets are also prepaid accounts because consumers can use them to store and access funds directly. The rule changes ensure that consumers continue to receive full federal credit card protections on their traditional credit card accounts while making it easier for them to link those accounts to digital wallets that can store funds. The changes also reduce potentially unnecessary complications and expense to consumers who link credit cards to digital wallets.
  • Extend the overall effective date of the rule by one year: The Bureau is sensitive to the concerns raised by commenters about needing more time to implement the rule, especially where they are making changes to packaging for prepaid cards sold in stores. The Bureau is thus extending the overall effective date of the rule by an additional year, to April 1, 2019. 

The Bureau also finalized certain other clarifications and minor adjustments to aspects of the prepaid rule. Click her for more information about the changes and the Bureau’s 2016 prepaid rule . 


Source: CFPB
Russian and Ukrainian individuals and entities designated
Treasury's Office of Foreign Assets Control has   announced   the designation of 21 individuals and 9 entities under four Executive Orders related to Russia and Ukraine, including three individuals and two entities related to Russia’s transfer of four turbines made by a Russian-German joint venture to Crimea. OFAC also identified 12 subsidiaries that are owned 50 percent or more by previously sanctioned Russian companies to provide additional information to assist the private sector with sanctions compliance. 
Weekly Regulatory Advocacy Report
The Weekly Advocacy Report provides links to information about a number of recent League, CUNA and NCUA regulatory and advocacy activities. 
   
Upcoming Education Sessions
The League has several education sessions coming up. Several focus on compliance issues. They are listed in calendar format on the League website.
   
League Consulting Department Staff
(800) 285-5300
Compliance Calendar
February
  • February 19, 2018: President's Day - Federal Holiday
March
  • March 16, 2018: Same-day ACH (NACHA) – Phase 3 of the implementation period for the rule.
April
  • April 1, 2018: Prepaid Accounts under the Electronic Fund Transfer Act/Regulation E and the Truth In Lending Act/Regulation Z (Date Extended)
  • April 29, 2018: 5300 Call Report Due to NCUA
May
  • May 11, 2018: Customer Due Diligence – CDD (FinCEN) – Effective date
  • May 28, 2018: Memorial Day - Federal Holiday
July
  • July 4, 2018: Independence Day - Federal Holiday
  • July 29, 2018: 5300 Call Report Due to NCUA
September
  • September 3, 2018: Labor Day - Federal Holiday
October
  • October 8, 2018: Columbus Day - Federal Holiday
November
  • November 12, 2018: Veterans Day (observed) - Federal Holiday
There's more available from InfoSight
InfoSight content is available from the League's website . Visit anytime to get sample policies, links to federal regulations and summaries of issues that are hot-topics at your credit union. 
 
Access to InfoSight is a benefit of League affiliation, so it is password-protected. If you don't have a password or if you have forgotten yours, click on the tan "Log In" button in upper right corner of the site; a box will open. Click on the blue wording to get your password.