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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|March 25, 2015|
|TIPs Bulletin #15-06||Foreign Language Translation Forms Revisions|
|TIPs Bulletin #15-05||NCUA Issues Warning to Consumers about “National Credit Union” Phishing Scam|
|January 28, 2015|
|TIPs Bulletin #15-04||2014 Residential Mortgage Loan Report|
|TIPs Bulletin #15-03||HMDA/LAR Reports|
|January 16, 2015|
|TIPs Bulletin #15-02||2015 Information Returns and Disclosures|
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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.
COMING SOON TO CUs: 'POLICYWORKS'
updated 05/18/15 02:44 PM
Also, Two FinCEN Announcements
Members of the California and Nevada Credit Union Leagues will have access to an extensive network of experts to answer their regulatory compliance questions when the Leagues’ Research and Information (R&I) Department transitions to PolicyWorks on June 1.
CONSUMER COMPLIANCE OUTLOOK
updated 05/11/15 04:12 PM
Plus, New TIPs Bulletin Posted
The First Quarter 2015 issue of Consumer Compliance Outlook is now available!