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
FACT Act Checklist
The Fair and Accurate Credit Transactions Act (FACT Act) amends the Fair Credit Reporting Act in several important ways.  It gives consumers the right to one free credit report every year from the credit reporting agencies, added new identity theft protections that allow consumers to place fraud alerts on their credit reports, and requirement of provisions to provide risk based pricing notices and credit scores to consumers in connection with denials or less favorable offers of credit. The Act also established a financial literacy commission and mandated a national financial literacy campaign to educate consumers on personal financial matters, including creating household budgets, managing spending more effectively, investment and wealth building, buying a home, and preparing for retirement. To assist credit unions with compliance, the FACT Act Checklist may provide helpful information.
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
Online lender pays $3.85M to settle FTC charges
The Federal Trade Commission has  announced  that Avant, LLC, an online lending company, has agreed to settle Commission charges that it engaged in deceptive and unfair loan servicing practices, such as imposing unauthorized charges on consumers’ accounts and unlawfully requiring consumers to consent to automatic payments from their bank accounts. The FTC charged that, in many cases, the company falsely advertised that it would accept payments by credit or debit cards, when in fact it rejected these forms of payments. The FTC also alleged that the company withdrew money from consumers’ accounts or charged their credit cards without authorization. In some instances, Avant charged consumers duplicate payments without authorization, improperly taking consumers’ monthly payments twice or more in one month. In one egregious example, one consumer’s monthly payment was debited from his account 11 times in a single day.  FTC Complaint
 
Source: FTC
Q&A Regarding Returned Mail
Q: When sending out member correspondence and statements we have “return service requested” on envelopes so we get notified by the post office of any address changes. When we receive these items back and a change of address label is attached with a new address we currently make the change and send an email to the member indicating a change has been made. An employee went to a conference and heard that this practice should not be used when it comes to issuing credit and debit cards. Why is this?
 
A: The NCUA’s guidance states the following:
 
III. Duties of Card Issuers Regarding Changes of Address (Card Issuers’ Rules) 8 A. IV. Duties of Users Regarding Address Discrepancies (Address Discrepancy Rules)
 
Address validation requirements
  1. Can a card issuer rely upon the US Postal Service’s change of address procedures to validate a change of address for purposes of the Card Issuers’ Rules?
 
The fact that a card issuer received a change of address notice from the US Postal Service is not sufficient to satisfy the validation requirements of the Card Issuers’ Rules. A card issuer that receives a notice of a change of address from the postal system regarding a cardholder’s address, and, within at least 30 days, a request for an additional or replacement card, may not issue the card unless it has validated the cardholder’s address using one of the procedures set forth in the Card Issuers’ Rules.
 
Additionally, credit and debit card issuers must develop policies and procedures to verify a request for a change of address that is followed closely (within 30 days or a longer period established in a creditor's or a financial institution's procedures) by a request for an additional or replacement card. A card issuer cannot issue the additional or replacement card until it has verified the validity of the change of address request in accordance with the financial institution's policies and procedures. If a change of address request has been verified before a request for an additional or replacement card is received, it is not necessary to verify the address a second time before issuing the card.
 
Source: NCUA
Other Articles of Interest
Advocacy Highlight
  • Support of SAFE Banking Act of 2019
  • HFSC Hearing on Megabanks
  • Veterans Member Business Lending Legislation
  • And more!
Keeping up with CUNA Advocacy
To stay abreast of the issues on which CUNA has provided input to lawmakers and regulators, here is a list of those topics .
 
CUNA Advocacy Update
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.
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.