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
Due to the Thanksgiving holiday, there will be no InfoSight on November 29.  Have a happy and filling Turkey Day!
Compliance Videos
Compliance Connection Videos
Our Compliance Connection channel provides credit unions with detailed information on the regulatory issues they face in the ever-changing world of compliance.
Compliance News
CFPB Issues Interpretive Rule on Screening And Training Requirements For Mortgage Loan Originators
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
Are Credit Report Fees Considered Finance Charges?
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
NCUA Board meeting agenda
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
Financial Regulators Revise Business Continuity Management Booklet
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
Advocacy Highlight
Senators introduce Veteran's MBL legislation
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
CUNA's Advocacy Resources
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 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.