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 News
Reserve Requirements – Regulation D Update
The Reserve Requirements – Regulation D topic has been updated to reflect the Interim Final Rule published by the Federal Reserve, effective on April 23, 2020. The rule allows credit unions to immediately suspend enforcement of the six-transfer limit and allow their members to make an unlimited number of convenient transfers and withdrawals from their savings deposits. 
 
The deposit reporting practices for credit unions has not changed with this rule, therefore credit unions should continue to report balances on their FR 2900 reports. Within this rule, there were also FAQs that have been incorporated into InfoSight for reference.
Compliance and Advocacy News & Highlights
Fed ends Savings '6 per Month' Limits
The Federal Reserve Board has   announced   an   interim final rule  t o amend Regulation D (Reserve Requirements of Depository Institutions) to  delete the six-per-month limit on convenient transfers from the "savings deposit" definition . The interim final rule allows depository institutions immediately to suspend enforcement of the six transfer limit and to allow their customers to make an unlimited number of convenient transfers and withdrawals from their savings deposits at a time when financial events associated with the coronavirus pandemic have made such access more urgent.
 
Because the Board no longer intends to use reserve requirements as a tool in monetary policy, the Board no longer considers it necessary to distinguish between transaction accounts and savings deposits with respect to reserve requirements.
 
The Board has also updated its   Savings Deposits Frequently Asked Questions  webpage . Questions 4 and 5 make it clear that depository institutions may continue to report accounts as "savings deposits" on their FR 2900 reports (this report will continue to be required), or report them as "transaction accounts." Question 10 explains that a depository institution may suspend enforcement of the limits on a temporary basis. Question 11 makes it clear that an institution's imposition of a fee for exceeding a transaction limit is not directly affected by the change.
The interim final rule is effective on publication in the  Federal Register
 
Source: Federal Reserve
Regulatory Treatment for Paycheck Protection Program Loans - Letter to Credit Unions (20-CU-11)
The NCUA Board recently approved an interim final rule amending regulatory requirements related to the Small Business Administration’s (SBA) Paycheck Protection Program (PPP) loans and the Board of Governors of the Federal Reserve System’s PPP Lending Facility (PPPLF) advances. These regulatory changes will become effective upon publication of the interim final rule in the Federal Register .
 
This letter discusses these regulatory changes and provides clarifications on PPP loans to credit union officials and non-members based on the most recent information from the SBA. The NCUA previously provided information about the PPP through Letter to Credit Unions 20-CU-06, Small Business Administration Loan Programs to Help Small Businesses and Members during the COVID-19 Pandemic . Subsequently, the SBA issued additional guidance on the PPP, including their responses to frequently asked questions .
 
Source: NCUA
NCUA’s Harper: Credit Unions Are Strong, but COVID-19 Presents Challenges
Federally insured credit unions at the start of the COVID-19 pandemic are strong, but they may face a more difficult environment than they ever have, NCUA Board Member Todd M. Harper said.
 
“The good news about this pandemic-induced recession, if there is any, is that federally insured credit unions, as a whole, have started in a strong economic position,” Board Member Harper said. “At the end of 2019, the system had a net worth ratio of 11.37 percent and a delinquency rate of just 71 basis points. But, we must remain vigilant and be prepared for the economic impact that is coming.”
 
Harper made these remarks remotely during the Mountain West Credit Union Association’s Annual Meeting on Thursday, April 23. The full text of his remarks , including the economic indicators he is watching, is available on the NCUA’s website .
 
Source: NCUA
NCUA: Mentoring Grants Available to Help MDIs
Small, low-income credit unions designated as minority depository institutions may apply for mentoring grants from May 1 through June 30, the National Credit Union Administration announced recently .
 
“Rural and underserved communities will be especially hard hit by the financial and economic disruptions resulting from the COVID-19 pandemic, and these are the areas that minority depository institutions predominately serve,” NCUA Chairman Rodney E. Hood said. “This mentoring program provides needed resources to help minority depository institutions continue to support the needs of their members and communities during this difficult time. I encourage eligible credit unions to consider applying for this program.”
 
Source: NCUA
Credit card money launderer pays $6.75M
The Federal Trade Commission has  announced  a Canadian company, RevenueWire, and its CEO, Roberta Leach, will pay $6.75 million to settle charges they laundered credit card payments for, and assisted and facilitated, two tech support scams previously sued by the FTC. RevenueWire entered into contracts with payment processors to obtain merchant accounts to process credit card charges for its own sales of eBooks and software. The contracts prohibited RevenueWire from submitting third-party sales through its merchant accounts. In reality, however, RevenueWire used its accounts to process credit card charges and collect payments from consumers on behalf of ICE and Vast, two companies that allegedly used tech support scams to bilk consumers out of millions of dollars.
 
Source: FTC
Articles of Interest
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. 
   
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.