January 2022 Compliance Vault

MT Minimum Wage Change

The poster reflecting the new $9.20 per hour state minimum wage is optional.

Signage Checklist

Use our updated list to review all the required signage in your branches.

More Reg E FAQ

The CFPB updated their FAQ on Reg E liability and fraud claims, and many of the new ones focus on P2P payments.

IRS Mileage Rate Increase

The 2022 rates set business travel at 58.5 cents starting Jan. 1, 2022.

Human Trafficking Awareness

This month, revisit the FinCEN advisory on identifying and reporting and read more about the problem in Montana.

Update to MLA Database

DoD schedules a Feb. 1 change to the MLA Database to add certain cadets and midshipmen as covered borrowers.

Consider Using ACET

NCUA provides a free and voluntary automated cybersecurity evaluation toolbox that allows credit unions to easily determine cyber preparedness.

Supervisory Priorities Released by CFPB

The CFPB released its Fall 2021 Supervisory Highlights in December, and the report reveals legal violations identified by the Bureau's exams in the first half of 2021. Those violations can indicate areas where the Bureau may focus future consumer protection efforts. Here are some of the key violations listed in the report

Mortgage servicers charging improper fees (including late fees and default-related fees) to borrowers enrolled in CARES Act forbearance and in some cases failing to refund fees until almost a year later.
Mortgage lenders violating the Equal Credit Opportunity Act by discriminating against African American and female borrowers in the granting of pricing exceptions. In these cases, examiners found the lender lacked oversight and control over how loan officers granted pricing exceptions. Examiners also found lenders who improperly utilized a questionnaire that contained explicit inquiries about an applicant’s religion.
Payday lenders improperly debiting or attempting to debit consumers’ bank accounts. In some instances where consumers called to authorize a loan payment by debit card, lenders’ systems erroneously indicated the transactions did not process, resulting in the improper debiting of additional, identical amounts or unauthorized attempts.

Compliance Conference

Puzzled by compliance? Unsure how it all fits into your role at the credit union? Join us March 22-23 in Helena for an in-person compliance and fraud conference.

We have an exciting agenda planned, but as previous attendees will tell you -- it's the networking and time with your peers that makes it invaluable!

A Few Thoughts...

If you read the BSA Email Series last month, you know a lot could be changing in 2022 as Montana rolls out its recreational cannabis program and FinCEN releases the details of the Anti-Money Laundering Act of 2020. In fact, in state cannabis news, not only did recreational sales start on Jan. 1, but Dawson County (Glendive area) already voted to move from a red to a green county and allow recreational dispensary sales. The previous cannabis county map is outdated, but we are expecting that the Cannabis Control Division will include a current map on their website soon. Watch for updates from MCU as pieces of the program are finalized.

Don't forget that we still have two days of OFAC emails coming later this month and that you can access the whole BSA email archive, including a recorded BSA for Staff webinar, on our Compliance Training Tools page.

We also got exciting news that two new products are being added to InfoSight -- the Reg CC Check Deposit Notice Generator (CDNG) and Account Insurance Estimator (AIE) will be launched on Feb. 23! Details are coming on pricing, but we can confirm the products will be free to credit unions with less than $100M in assets. Ty Parker -- who many of you remember from his days teaching check law at compliance school -- created the products, and we'll be engaging him to provide a webinar to overview them soon after launch.

~Donya

Federal agencies, including the Dept. of Justice, FBI, CFPB, FTC, and U.S. Postal Inspection, are teaming up to educate consumers about the dangers of becoming a money mule in financial fraud. The Money Mule Initiative provides resources to assist your credit union in educating your staff, members, and communities.

Let us know what you are seeing at your credit union so we can keep other credit unions in Montana informed. Encourage members to report at reportfraud.ftc.gov.