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
|Arnold Ramirez, Research and Information Consultant for the California and Nevada Credit Union Leagues|
According to Regulation E §1005.20, there are certain conditions that must be met for an issuer or seller of a general-use prepaid card which determine whether an expiration date may be applied.
Before a general-use prepaid card is purchased, the issuer or seller must disclose to the consumer the information about dormancy, inactivity, service fee, expiration date, and the toll-free telephone number. If the issuer or seller has a website, it must also disclose that site so the consumer can obtain fee information.
These disclosures must be made on the card. A disclosure made in an accompanying terms-and-conditions document—or on the packaging surrounding a certificate or card, or on a sticker or other label affixed to the certificate or card—does not constitute a disclosure on the certificate or card.
The fees—and terms and conditions of expiration—that are required to be disclosed prior to purchase may not be changed after purchase.
FINCEN ISSUES CDD FAQs
updated 07/25/16 10:52 AM
Plus, HMDA Resources Published
The Financial Crimes Enforcement Network (FinCEN) issued Frequently Asked Questions to help financial institutions, including credit unions, understand the scope of the new Customer Due Diligence (CDD) Requirements that were published in May. The CDD rules became effective on July 11, 2016 with compliance required by May 11, 2018.
CFPB PAYDAY LOANS WEBINAR
updated 07/18/16 02:40 PM
And, CUNA/League Compliance Tools
The Consumer Financial Protection Bureau (CFPB) is hosting a webinar on the recent Notice of Proposed Rulemaking on Payday, Vehicle Title, and Certain High-Cost Installment Loans on July 26.