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|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.
CA PRIVACY NOTICES STILL REQUIRED
updated 02/02/16 08:35 AM
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The FAST Act made changes to federal annual privacy notice requirements. However, it did not change California privacy notification requirements, which are applicable to all financial institutions doing business in California. California state annual privacy notifications are still required, depending on what information is shared and with whom.
CUSOs TO REGISTER WITH NCUA REGISTRY
updated 01/26/16 10:07 AM
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In a letter sent to credit unions, credit union service organizations (CUSO) have 60 days to register with the National Credit Union Administration’s (NCUA) CUSO Registry, the new online system for CUSOs to report their operational and financial information directly to the agency. The registration period begins Feb. 1 and ends March 31.