Compliance and Risk Alert:
Overdraft NSF Risk Management
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Dear CU friends:
As many of you know, last week the CFPB issued new guidance related to NSF/overdraft fees and returned deposited item fees. This is in addition to other recent actions and the ongoing onslaught of NSF litigation. We have prepared the attached compliance and risk alert to help your credit union understand these recent actions and their impact on your credit union. If you have questions or would like assistance in evaluating your credit union’s compliance risk, disclosures, and practices, we’d be happy to talk with you.
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Hal Scoggins has been providing legal advice to credit unions since 1991, focusing on state and federal regulatory compliance, deposit and lending operations, contract and business matters, corporate governance, CUSOs, and all other aspects of financial service delivery. He frequently conducts seminars on legal matters for the Northwest Credit Union Association, Credit Union National Association councils, local chapters, and other trade groups.
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Brian Witt represents credit unions and CUSOs on corporate, operational, compliance, executive compensation and financial service delivery matters. Practicing law for more than 30 years, Brian has vast experience working with credit unions at all levels from the teller line to the Board room. Brian has developed extensive compliance resources for member response management, vendor management and contract review, information security programs, security response guidelines, online delivery of financial services, and credit union consumer and business lending.
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With a background in banking and business, Kelley Hodney brings considerable experience and working knowledge in the areas of consumer and commercial law relevant to assisting financial service providers on matters related to legal compliance, and creditors' rights litigation. She monitors regulatory changes and legislation at the federal level and in Oregon, Washington, and California that affects financial service providers.
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Mark Robey counsels credit unions on compliance with Federal and state laws and regulations including consumer protection regulations of the CFPB, the Federal Reserve, the National Credit Union Administration, the Federal Communications Commission and the Federal Trade Commission. He guides credit unions on effective operations in compliance with agency rules. Mark is known for his work on compliance guides including summary and detailed analyses, along with compliance checklists and model policies.
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Copyright © 2022 Farleigh Wada Witt. All Rights Reserved.
The contents of this publication are intended for general information only and should not be construed as legal advice or opinion on specific facts and circumstances.
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