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
Payday Alternative Loans
In light of the recent extension to November 19, 2020 by the CFPB to the mandatory provisions of the Payday Lending Rule and mentioned in an article in this newsletter, the Payday Alternative Loans page in the Loans and Leasing channel has been updated to reflect this change.
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
CFPB Delays Compliance Date for Mandatory Underwriting Provisions in Payday Lending Rule
 The Consumer Financial Protection Bureau (CFPB) issued a final rule to delay the August 19, 2019 compliance date for the mandatory underwriting provisions of the November 17, 2017 final rule governing Payday, Vehicle Title, and Certain High-Cost Installment Loans (Payday Lending Rule). The compliance date is delayed by 15 months, to November 19, 2020.

The Payday Lending Rule governs the underwriting of certain personal loans with short term or balloon-payment structures, as well as lenders’ payment withdrawal practices for those loans and certain additional installment loan products. Based on comments received in response to two separate February 6, 2019 notices of proposed rulemaking (NPRM) regarding whether the CFPB should rescind the mandatory underwriting provisions of the 2017 Final Rule (Reconsideration NPRM) and on whether it should delay the compliance date for those same provisions (Delay NPRM), the CFPB issued this final rule to delay the August 19, 2019 compliance date for the mandatory underwriting provisions, to November 19, 2020. This delay will allow for an orderly conclusion to its separate rulemaking process to reconsider the mandatory underwriting provisions.
After reviewing the comments received in response to the February 2019 Delay NPRM, the CFPB decided to revisit the mandatory underwriting provisions on the grounds set out in the Reconsideration NPRM because if the mandatory underwriting provisions went into effect while the CFPB was in the process of reconsidering these provisions, potential consequences could undermine effective reconsideration of the 2017 Final Rule. In addition, the CFPB is making certain corrections to address several clerical and non-substantive errors it has identified in the 2017 final rule.

For more information, see the CFPB’s Final Rule page.  And for a Table of Contents for the Payday Delay Final Rule, see  Table of Contents.

Source: CFPB
FCC Clarifies that Voice Providers Can Block Robocalls by Default
The Federal Communications Commission on Thursday approved a  declaratory ruling allowing voice service providers to block calls by default (as opposed to a consumer opt-in) based on call analytics that target unwanted calls, as long as their customers are informed and have the opportunity to opt-out of the blocking.

The ruling clarified that Telecom providers may also offer their customers the choice to opt-in to tools that block calls from any number that does not appear on a customer’s contact list or other “white lists.” This option would allow consumers to decide directly whose calls they’re willing to receive, based on the contact list in a person’s smart phone. 

The FCC is urging voice providers to implement the so-called “SHAKEN/STIR” caller ID authentication framework by the end of 2019. Failure to do so could result in further rulemaking to require implementation of the technology. SHAKEN/STIR stands for Signature-based Handling of Asserted Information Using toKENs (SHAKEN) and the Secure Telephone Identity Revisited (STIR) -- it is a protocol for authenticating phone calls with the aid of cryptographic certificates.

In addition, the FCC is seeking comment on whether to:
  • Create a safe harbor for providers that block maliciously spoofed calls (so that caller ID cannot be authenticated) and that block calls that are “unsigned”;
  • Require voice service providers that block calls to ensure that emergency calls reach consumers; and
  • Provide protections and remedies for callers whose calls are erroneously blocked.

Source: FCC
CUNA Backs BSA, NFIP, Financial Literacy Bills Prior to Markup
CUNA wrote in support of  four regulatory relief bills being marked up by the House Financial Services Committee this week.
The bills are:
  • The Corporate Transparency Act of 2019 (H.R. 2513), which would address the redundancies, unnecessary burdens, and opportunities for efficiencies within the Bank Secrecy Act/Anti-Money Laundering (BSA/AML) statutory framework. CUNA notes that regulatory regimes like BSA should be a scalable framework to help smaller institutions;
  • The National Flood Insurance Program (NFIP) Administration Reform Act of 2019(H.R. 3111), which would make administrative reforms to the NFIP;
  • The NFIP Reauthorization Act of 2019 (H.R. 3167), which would extend NFIP through Sept. 30, 2024. While CUNA supports this bill and H.R. 3111, it also called for a long-term, sustainable solution to restore certainty to the market; and
  • The House Financial Literacy Act of 2019 (H.R. 2162), which would require the Secretary of the Department of Housing and Urban Development to provide a 25-basis point discount in FHA insurance premiums for first-time homebuyers that complete a financial counseling course.

Source: CUNA
Advocacy Highlight
CUNA Advocacy Update
To stay abreast of the issues on which CUNA has provided input to lawmakers and regulators, here is a list of those topics . Additional updates include:





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.