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Research & Compliance     

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Research & Compliance

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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
October 15, 2014
TIPs Bulletin #14-23 SB 1050—Notaries Public: Verification of Identity: New Boxed Notice Required
 
October 1, 2014
TIPs Bulletin #14-22 Assembly Bill 2293 – Mandates Baseline Insurance Requirements for Transportation Network Companies
TIPs Bulletin #14-21 California Unclaimed Property Holder Notice Reports Coming Due
TIPs Bulletin #14-20 Assembly Bill 2742 – Revised Model Language for California Consumer Caution and Home Ownership Counseling Notice
   
September 23, 2014
TIPs Bulletin #14-19 AB-1858 Change to Financing Statement
   
September 18, 2014
TIPs Bulletin #14-18 Reg Z and Reg M Exemption Threshold Adjustments
   
 
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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'NMLS' RENEWAL PERIOD BEGINS NOV. 1
updated 10/17/14 01:01 PM
Guidance for Mortgage Loan Originators
The Nationwide Mortgage License Servicing and Registry (NMLS) annual renewal period begins Nov. 1 and ends Dec. 31, where mortgage loan originator registrants must renew their registrations annually, according to federal regulations.

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FED'S UPCOMING FAIR LENDING WEBINAR
updated 10/10/14 09:09 PM
Also, Unclaimed Property Workshop
The Federal Reserve Bank of San Francisco is holding a webinar on fair lending issues and hot topics, where representatives from seven federal agencies will discuss a variety of emerging fair lending issues and hot topics.

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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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Comment Letters
The Leagues write letters in response to proposed legislation and regulations that affect your credit union’s ability to serve members.