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Institutions subject to Consumer Financial Protection Bureau (CFPB) jurisdiction, including credit unions and indirect auto lenders, should take steps to ensure they are operating in compliance with the Equal Credit Opportunity Act (ECOA) and Regulation B as applied to dealer-markup and compensation policies.
Click here to read the entire Asked and Answered column within the April/May edition of Credit Union Digest on page 20.
Fair Lending Exam Update
The Credit Union National Association (CUNA) Compliance Blog has posted valuable information on the National Credit Union Administration’s (NCUA) fair lending examinations.
The agency completed 41 off-site supervision contacts last year and plans to complete approximately 50 off-site supervision contacts in 2014.
NCUA has implemented a risk-focused approach to conducting on-site examinations and off-site supervision contacts. Examinations include a transactional review of fair lending risk factors, plus a review of the credit union’s fair lending compliance management system.
Examination focal points and contact scoping are based on multiple factors, including Home Mortgage Disclosure Act (HMDA) reporting outliers and violations identified in safety and soundness examinations, or through the complaint process. Supervision contacts also review a credit union’s fair lending compliance management system.
Click here for more information and resources.
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
NCUA Hosts Webinar on New System
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.