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Research & Compliance     

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Research & Compliance

The answers you need—when you need them!
When technical challenges or complex situations arise at your credit union, turn to the Leagues’ Research & Information (R&I) Department. Our mission is to provide technical, compliance, operational, economic, and regulatory information in an understandable and easily accessible way.
     
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A resource for credit unions in CA & NV, providing credit union financial and economic trend analysis, brought to you by your Leagues in partnership with CUNA & Affiliates.

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TIPs Bulletins
The Technical Information Procedure (TIPs) bulletins are great tools to help credit union staff understand recent changes in laws and regulations and how they may affect the credit union. TIPs bulletins address current mandatory compliance issues and changes to federal and state regulations. Continue for complete list of current TIPs Bulletins
July 16, 2014
TIPs Bulletin #14-14 Canada’s Anti-SPAM Legislation (CASL) and Its Impact to U.S. Credit Unions
   
June 30, 2014
TIPs Bulletin #14-13 Voluntary Liquidation
TIPs Bulletin #14-12 Annual Indexing of HUD’s Basic Statutory Mortgage Limits for Multi-Family Housing Programs
   
June 10, 2014
TIPs Bulletin #14-11 Interim Rule - Exchange of Mutilated Paper Currency
   
 
CURoots Services

Shared Compliance Services
CURoots offers a variety of services to help you keep pace with ever-changing regulatory compliance while you focus on day-to-day credit union business.

Internal Audit Services
CURoots can help your credit union identify potential issues, assess risk, and save valuable time and resources by providing expert assistance for your auditing needs.


From the Editors of CU Weekly

IN FOCUS: INDIRECT AUTO LENDING
updated 03/29/13 07:56 AM
Take Note of CFPB, NCUA Guidance
On March 21, the CFPB issued a bulletin—CFPB Bulletin 2013-02—regarding compliance with the Equal Credit Opportunity Act (ECOA) and its implementing regulation, Regulation B, as they pertain to indirect auto lending programs that allow auto dealer interest-rate markups.

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:

  • Imposing controls on dealer markup and compensation policies, or otherwise revising dealer markup and compensation policies, and also monitoring and addressing the effects of those policies in the manner described below, so as to address unexplained pricing disparities on prohibited bases; or
  • Eliminating dealer discretion to mark up buy rates and fairly compensating dealers using another mechanism, such as a flat fee per transaction, that does not result in discrimination.

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.

 
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TIPs, FinCEN PUB, HANDBOOK UPDATE
updated 07/21/14 12:44 PM
The Latest in Compliance
A new TIPs Bulletins (Technical Information and Procedures) has been posted by the California and Nevada Credit Union Leagues on Canada’s anti-SPAM legislation, which went into effect July 1 and is similar to the U.S. government’s CAN-SPAM Act of 2003.

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CFPB ISSUES INTERPRETIVE RULING
updated 07/14/14 03:48 PM
'Ability to Repay' Discussed
The Consumer Financial Protection Bureau (CFPB) has issued an interpretive rule to clarify that when a borrower dies, the name of the borrower’s heir generally may be added to the mortgage without triggering the bureau’s Ability-to-Repay Rule.

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D.J.'s Economix
Leagues Chief Economist Dwight Johnston continually provides economic and market analysis that is both informative and entertaining. Continue for daily and monthly commentary, rate forecasts, and economic updates.
Resources
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The Leagues write letters in response to proposed legislation and regulations that affect your credit union’s ability to serve members.