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.
Answers to your crucial questions can be less than one business day away. Post your question here, and a talented compliance professional will get back to you quickly! Or if you prefer, call the PolicyWorks compliance hotline to speak directly with our knowledgeable consultants.
Compliance Hotline: (844) 731-6072
Continue for Ask PolicyWorks
|Jan Owen, Commissioner of the Department of Business Oversight (DBO)|
Illegal payday loans made over the Internet are made possible in California by credit and debit transactions that pass through the Automated Clearing House (ACH) network.
Owen is urging state-licensed credit unions to monitor transactions with any unlicensed lender and immediately report potential violations to DBO.
Credit unions that are Originating Depository Financial Institutions (ODFIs) should look to discontinue any ACH transactions or refrain from doing business with these unlicensed payday lenders. Credit unions that are Receiving Depository Financial Institutions (RDFIs) should look to monitor member complaints of unauthorized transactions, particularly those involving online payday lending companies.
If any credit union detects a trend of a high number of unauthorized claims from a certain lender, it should notify the DBO. It may also trigger a suspicious activity report (SAR) filing. If not done already, the credit union may want to implement procedures allowing it to identify such trends.
Owen's department is actively pursuing, with cease-and-desist orders, unlicensed companies who are offering payday loans to California consumers over the Internet in violation of California law.
UNCLAIMED PROPERTY HANDBOOK
updated 04/26/16 07:15 AM
Plus, Title XIV Mortgage Updates
California State Controller's Office has issued an updated Unclaimed Property Holder Handbook with changes to reflect:
CREDIT CARD SUBMISSION GUIDANCE
updated 04/18/16 12:02 PM
Plus, Compliance Advice Webinar
The Consumer Financial Protection Bureau (CFPB) has issued guidance for credit card issuers with simplified instructions for making the required submissions under Regulation Z. Last year, the CFPB temporarily suspended this rule until April 30, 2016. Issuers have to submit credit card agreements to the Bureau by May 2, 2016, and quarterly thereafter.