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
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InfoSight – Advertising > Advertising Deposit Accounts
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Is your credit union thinking of offering a new type of deposit account? Has it been some time since anyone reviewed your advertising for the current accounts you offer? Do you know all of the components that need to be included in your deposit account advertising? To be sure you are including all you need, be sure you review the requirements for advertising deposit accounts on the
Advertising > Advertising Deposit Accounts
topic!
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Compliance Outlook for Q1 and Q2 2018
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As many of you know, CUNA recently hosted a webinar on the EU's General Data Protection Regulation. The webinar focused on the regulation being implemented overseas, its potential impact on US credit unions, and the prospects for similar restrictions in the US – whether through legislation or industry self-policing.
For those that were unable to attend the live webinar, or would like a second listen to the webinar, the webinar is now available.
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Windows 10 Upgrade for ATMs – Another Upcoming Deadline for Credit Unions
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Many credit unions currently use Windows 7 as the operating system for their ATMs. In 2020, this version of all ATMs using Windows 7 will need to be able to use Windows 10. This may be as easy as a software upgrade, or it may mean a complete replacement of one or more ATMs. Although this deadline seems lightyears away, it will take time for all ATMs to be verified, tested, and made compliant.
Click here to read the latest article from Credit Union Times about this important software change.
Source: Credit Union Times
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What You May Not Know About Human Trafficking: The Many Faces of Forced Labor
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A new human trafficking report was issued last March by an organization by the name of Polaris. This organization’s mission is to eradicate modern-day slavery by:
(1) responding to victims effectively and immediately (via Hotline),
(2) equip key stakeholders and communities to address and prevent human trafficking (credit unions are considered stakeholders), and
(3) disrupt the business of human trafficking through targeted campaigns.
Generally, when we hear the term “human trafficking” many of us envision young women being forced into prostitution. While recognizing that the sex trade is a large segment of human trafficking, this new study provides information on many other types of human trafficking to help broaden our awareness. As a result of this study we can expect that new red flags may emerge over the coming months. In the meantime, understanding that human trafficking can come in many different forms may help you better determine whether an activity is, or is not, suspicious.
Polaris has identified 25 types of human trafficking. Some of the listed business types in the report are likely not surprising to most of us, such as escort services, massage parlors, strip clubs, and pornography. However, forced labor in many of the businesses we come in contact with daily is believed to be even more prevalent than sex trafficking. Polaris believes that labor trafficking cases in the U.S. are chronically underreported due to a lack of awareness about the issue and a lack of recognition of the significant vulnerability of workers in the U.S. labor force. Also, many exploited workers do not even know they are being exploited.
Source: CUNA Compliance Blog
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CUNA Submits Comments to FCC Regarding Reassigned Numbers Database
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CUNA filed a comment letter to the FCC
regarding its proposal to create a Reassigned Numbers Database for purposes of compliance with the Telephone Consumer Protection Act (TCPA). Our comments state that the Commission should establish a comprehensive, easy-to-use and affordable reassigned numbers database and provide a safe harbor from TCPA liability for calling a reassigned number where the caller utilized the database, along the lines of the Do Not Call registry provisions.
“Despite the limited, informational nature of their communications, credit unions nonetheless find themselves the target of frivolous TCPA litigation. A recurring concern is reassigned numbers,” the letter reads. “Like telephone consumers generally, credit union members frequently change their contact numbers that were provided to the credit union, and do not necessarily think to immediately inform the credit union of the change. The credit union may then call the number to provide information without any knowledge that the number has been reassigned, potentially exposing it and its member-owners to liability.”
CUNA believes the FCC should also:
- Ensure the database is affordable and as easy to use as possible. CUNA suggests a fee structure similar to the national “Do Not Call” list, for which users pay a per-area code dee, with a cap on the maximum cost; and
- Create a safe harbor for callers that utilize the database, structured similarly to the safe harbor established by the national “Do Not Call” list in which a caller demonstrates that it checks numbers against the database as part of its routine business practices.
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USAA Files Suit Against Wells Fargo For RDC Patent Infringement
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USAA filed suit against Well Fargo last week in U.S. District Court for the Eastern District of Texas for intellectual property infringement stemming from Well’s remote deposit capture (RDC) products. USAA has been seeking licensing fees from credit unions and banks that use remote deposit capture technology. The complaint was filed Thursday in U.S. District Court for the Eastern District of Texas.
This appears to be the first lawsuit that USAA has filed against a financial institution to enforce their patents although USAA had previously litigated RDC patents with technology vendor Mitek. CUNA has been following this issue closely and had recently surveyed credit unions asking for details on their RDC offerings to further analyze the issue.
An information webinar with CUNA staff and outside counsel is available here.
Source: CUNA Removing Barriers Blog
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U.S. Faster Payments Council Survey
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Last week CUNA hosted a webinar that provided comprehensive information on the Federal Reserve Board's proposed U.S. Faster Payments Council. If you were unable to join,
you can listen to a recording here
.
As discussed on the webinar,
please use the following survey to
provide your feedback on the proposed U.S. Faster Payments Council governance framework via a brief, 8-question survey.
The U.S. Faster Payments Council represents the work of the Governance Framework Formation Team, a diverse group of payments industry stakeholders that was established by the former Faster Payments Task Force to advance the first recommendation of its final report. The GFFT's goal is to develop a faster payments governance framework, inclusive of all stakeholders, to make decisions to facilitate interoperability and achieve ubiquity of faster payments in 2020, as well as navigate future challenges as technology and end-user needs evolve.
Establishing an industry governance framework is critical to sustaining progress and successfully executing many of the task force's recommendations, and the Governance Framework Formation team appreciates your feedback and participation in this important next step in the payment system improvement initiative.
Source: CUNA Advocacy
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Keeping up with CUNA Advocacy
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The CUNA Advocacy Update is published at the beginning of every week and keeps you on top of the most important changes in Washington for credit unions--and what CUNA is doing to monitor, analyze, and influence government agencies and federal law. To receive this update, click on “Get CUNA Updates” on the
CUNA Advocacy page. Additional Advocacy efforts may also be found under
CUNA’s Removing Barriers blog. With the recent updates to CUNA’s website, Advocacy information has also changed. To view recent advocacy issues and see ways your credit union can become involved, visit the
Priorities or
Actions pages.
Source: CUNA
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Weekly Regulatory Advocacy Report
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The Weekly Advocacy Report provides links to information about a number of recent League, CUNA and NCUA regulatory and advocacy activities.
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Upcoming Education Sessions
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The League has several education sessions coming up. Several focus on compliance issues. They are listed in calendar format on the League website.
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League Consulting Department Staff
(800) 285-5300
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July
- July 1, 2018: Regulation CC Amendments – Availability of Funds and Collection of Checks
- 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
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There's more available from InfoSight
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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.
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