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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Due to the Thanksgiving holiday, there will be no InfoSight on November 29.
Have a happy and filling Turkey Day!
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Compliance Connection Videos
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Our
Compliance Connection channel
provides credit unions with detailed information on the regulatory issues they face in the ever-changing world of compliance.
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CFPB Issues Interpretive Rule on Screening And Training Requirements For Mortgage Loan Originators
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The Consumer Financial Protection Bureau (Bureau) recently
issued an interpretive rule
clarifying screening and training requirements for financial institutions which employ loan originators with temporary authority. The rule will be effective on November 24, 2019.
On November 15 , 2019, the Bureau updated the
small entity compliance guide
to reference the guidance in the interpretive rule on Regulation Z Screening and Training Requirements for Mortgage Loan Originators with Temporary Authority.
Source: CFPB
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Are Credit Report Fees Considered Finance Charges?
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Question:
Roger, the new lending officer at ABC Federal Credit Union, is not sure whether credit report fees should be considered finance charges under Regulation Z so he has asked Carol, the credit union’s compliance officer, for help. How should Carol respond to Roger concerning credit report fees?
- A. Credit report fees are always considered finance charges under Regulation Z.
- B. Credit report fees are never considered finance charges under Regulation Z.
- C. Credit report fees are considered finance charges on transactions secured by real property and are not considered as finance charges for all other loans.
- D. Credit report fees are not considered finance charges on transactions secured by real property but are considered finance charges for all other loans.
Answer:
The correct answer is “D.” Credit report fees are not considered finance charges on transactions secured by real property but are considered finance charges for all other loans.
Regulation Z Section 226.4(b)(4) indicates that credit report fees are considered finance charges unless specifically excluded. Paragraph (c) states that credit report fees are excluded from the finance charge for transactions secured by real property or in a residential mortgage transaction if the fees are bona fide and reasonable in amount.
Source: CUNA Compliance Blog
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NCUA Board meeting agenda
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The NCUA has posted the agenda for its 10:00 a.m. EST November 21, 2019, Board meeting. The matters to be discussed include the quarterly report of the Share Insurance Fund, guidance on prohibitions imposed by statute, and Part 722 (Real Estate Appraisals) of NCUA Rules and Regulations.
Source: NCUA
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Financial Regulators Revise Business Continuity Management Booklet
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The members of the
Federal Financial Institutions Examination Council (FFIEC) recently emphasized
that examiners understand how management of banks and other regulated entities, including depository financial institutions, nonbank financial institutions, bank holding companies, and third-party service providers, have prepared their operations to avoid disruptions and to recover services.
The
updated Business Continuity Management booklet
focuses on enterprise-wide approaches that address technology, business operations, testing, and communication strategies critical to the continuity of the business. The booklet describes principles and practices for information technology (IT) and operations designed to achieve safety and soundness, consumer financial protection, and compliance with applicable laws, regulations, and rules.
Source: FFIEC
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Senators introduce Veteran's MBL legislation
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The day after Veteran's Day, Senators Dan Sullivan and Mazie Hirono introduced S. 2843, the Veteran's Member Business Loan Act. This legislation would exempt loans to veteran-owned businesses from the member business lending cap. Specifically, the bill would amend the Federal Credit Union Act to exclude extensions of credit made to veterans from the MBL definition. Credit unions are restricted in business lending by current law to 12.25% of their total assets. Stay tuned for more details on this legislation.
Source: MCUL
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CUNA's Advocacy Resources
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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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There's more available from InfoSight
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InfoSight
content is available 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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