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
Compliance Calendar
InfoSight provides an up-to-date calendar showing upcoming dates important to the compliance community. Coming up on June 21 is the Effective Date for Return for Questionable Transaction and on July 1 st is the Effective Date for Loans in Areas Having Special Flood Hazards. Log into InfoSight today to be sure you are prepared when these regulations become effective and to see what other compliance dates are coming up this year.
Compliance Videos
Compliance Connection Video
In this video , League InfoSight CEO Glory LeDu talks about the highlights from the 4 th Quarter of 2018 and the 1 st Quarter of 2019.

When S.2155, the Economic Growth, Regulatory Relief, and Consumer Protection Act, passed in 2018 there was a lot to understand! Glory LeDu, League InfoSight CEO, provides Part 1 in this short video to break it down for you.
Compliance News
CUNA Provides First-Quarter 2019 Update to the Credit Card MLA Fee Comparison Spreadsheet 
First Quarter 2019 update to the credit card MLA Fee Comparison Spreadsheet is now available.
The recently-updated First-quarter 2019 fee comparison spreadsheet has been downloaded in CUNA’s Compliance Community under the Compliance Resources Tab and is also available under the Resources tab in the MLA topic in CUNA’s e-Guide. In each location you will also find the fourth-quarter spreadsheet from December 2018, the third-quarter spreadsheet from September 2018, the second-quarter spreadsheet from June 2018, the first quarter spreadsheet from March 2018 and the initial spreadsheet from September 2017, in case you need to refer to historical data.
 
Source: CUNA Compliance Blog
Bureau updates CIDs policy
Consumer Financial Protection Bureau  recently announced  changes to its policies regarding Civil Investigative Demands to ensure they provide more information about the potentially wrongful conduct under investigation.

Bureau-issued CIDs will provide more information about the potentially applicable provisions of law that may have been violated. CIDs will also typically specify the business activities subject to the Bureau’s authority. In investigations where determining the extent of the Bureau’s authority over the relevant activity is one of the significant purposes of the investigation, staff may specifically include that issue in the CID in the interests of further transparency.

The Bureau said the new policy takes into account recent court decisions about notifications of purpose, and is consistent with a 2017 report by the Bureau’s Office of Inspector General that emphasized the importance of updating Office of Enforcement policies to reflect such developments. The new policy is also consistent with comments the Bureau received in response to the Requests for Information it issued in 2018, seeking feedback about various aspects of its operations, including its use of CIDs in enforcement investigations.
CFPB Updates Prepaid Small Entity Compliance Guide
The Bureau has published updates to the Prepaid Small Entity Compliance Guide reflecting previously issued resources to help prepaid account issuers submit account agreements using Collect, the Bureau’s online channel for submissions. 

Source: CFPB
Interagency update on private flood insurance rule
Staff of the Federal Reserve, Farm Credit Administration, FDIC, NCUA and the OCC will conduct a one-hour Outlook Live webinar at 2 p.m. EDT on Tuesday, May 14, to discuss the private flood insurance rule published on February 20, 2019. Topics will include:
  • Mandatory acceptance of private flood insurance;
  • Mandatory acceptance Compliance Aid;
  • Discretionary acceptance of private flood insurance;
  • Flood Coverage provided by Mutual Aid Societies; and
  • Preparations to comply with the Rule

Advance registration  is recommended.
 
Source: Interagency Update
CFPB Issues RFI regarding remittance rule
The CFPB has issued a Request for Information (RFI) regarding potential regulatory changes to the Bureau’s Remittance Rule. The RFI seeks information on two specific areas of the rule.
  • Temporary Exception Expiration Questions: First, the RFI seeks information and evidence that may inform possible changes to the rule that would not eliminate, but would mitigate the effects of the expiration of a statutory exception for certain financial institutions. The Electronic Funds Transfer Act expressly limits the length of the temporary exception in the Remittance Rule to July 21, 2020 and does not authorize the Bureau to extend this term. Therefore, the exception will expire on July 21, 2020 unless Congress changes the law. 
  • Institution and Transaction Coverage Questions: In addition, the RFI seeks information and evidence related to the scope of coverage of the rule, including whether to change a safe harbor threshold in the rule that determines whether a person makes remittance transfers in the normal course of its business, and whether an exception for small financial institutions may be appropriate.
 

The Bureau has also published a revised version of the Remittance Rule assessment report . The original report inadvertently understated the approximate dollar volume of remittances made by depository institutions. The understatement does not affect any of the report’s conclusions. 
 
Source: CFPB
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
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.