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|August 8, 2014|
|TIPs Bulletin #14-16||CA Local Agency Deposits Weekly Reports Can Be Submitted Electronically|
|August 8, 2014|
|TIPs Bulletin #14-15||MasterCard Revised Standards – Limitation of Liability of Cardholders for Unauthorized Use (“Zero Liability”)|
|July 16, 2014|
|TIPs Bulletin #14-14||Canada’s Anti-SPAM Legislation (CASL) and Its Impact to U.S. Credit Unions|
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The CFPB is concerned with indirect auto lender markup and compensation policies with auto dealers, stating that the incentives these policies create and the discretion they permit cause significant risk for pricing disparities on a prohibited basis. An auto lender may be liable for such pricing disparities under the ECOA for both disparate treatment and disparate impact.
The CFPB Bulletin includes discussion on limiting fair lending risk in indirect auto lending, including:
Most credit unions are not subject to CFPB jurisdiction, and enforcement authority for ECOA and Regulation B violations lies with the National Credit Union Administration (NCUA) for federal credit unions and Federal Trade Commission (FTC) for state credit unions.
However, couple the CFPB Bulletin with NCUA’s recent Letter to Federal Credit Unions regarding fair lending exams, 13-FCU-02, and it's clear that credit unions should take note. If your credit union has a markup and compensation policy for indirect lending, please review the CFPB Bulletin for guidance.
Does your credit union have the resources to effectively monitor your indirect lending portfolio for possible ECOA violations and address the effects of dealer markup and compensation policies? Are changes needed to compensate dealers in a different way, such as a flat fee per transaction method? These are relevant questions to ask as you review the CFPB Bulletin.
NCUA’s Letter to Federal Credit Unions includes additional resources to review and ensure your credit union has a strong fair lending compliance program. These resources include a new NCUA Fair Lending Guide and a Fair Lending Webinar scheduled for April 4.
TIPs ISSUED ON WEEKLY E-FILING BILL
updated 09/02/14 10:16 AM
Also, Mortgage Servicing Transfer Guidance
The California and Nevada Credit Union Leagues have published a new TIPs Bulletin on recently passed California Assembly Bill 2298, which allows credit unions and other financial institutions that hold local agency deposits to submit weekly reports to the Department of Business Oversight (DBO) electronically rather than through U.S. Mail.
EXCEPTION ISSUED ON REMITTANCE RULE
updated 08/25/14 09:28 PM
CUs Can Estimate Fees
A final rule issued by the Consumer Financial Protection Bureau (CFPB) extends a temporary exception to its remittance transfer rule that allows credit unions and other depository institutions to estimate certain remittance pricing disclosures when specific pricing information is not available.