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The guidance encourages financial institutions to effectively communicate with borrowers about the pending reset, and provides broad principles for managing risk as HELOCs reach their end-of-draw periods.
Other regulators jointly issuing this guidance include the Office of Comptroller of the Currency (OCC), Federal Reserve Board of Governors (FRB), and Federal Deposit Insurance Corp. (FDIC). To view the seven-page document, click here.
Additionally, NCUA Board Chairman Debbie Matz has issued Letter to Credit Unions (14-CU-08), encouraging credit unions to review the interagency guidance to ensure their practices align with NCUA’s risk management expectations.
State Controller’s Newsletter
The California State Controller’s Office has published its summer newsletter, which includes a reminder on the change to the threshold for aggregate reporting from $50 to $25, effective July 1, 2014.
For more information and clarification on this change, credit unions can review the California and Nevada Credit Union Leagues’ TIPs Bulletin 13-45 (October 2013).
The state controller’s newsletter also includes information and examples on properly reporting safe-deposit boxes, holders’ claims for reimbursement, and owner reunification efforts.
MLA DATABASE FEB. 15 DEADLINE
updated 02/09/16 08:00 AM
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Credit unions seeking a safe harbor under the Department of Defense’s (DoD) Military Lending Act (MLA) final rule will have two new options come Oct. 3, 2016: 1) A credit union may verify a borrower’s status on the DoD’s database, or 2) a credit union may use a consumer report obtained from a nationwide consumer reporting agency to determine whether a borrower is a “covered borrower.” Credit unions interested in utilizing the first option have until Feb. 15, 2016 to notify the Defense Manpower Data Center (DMDC) of their intent. This may be done by emailing the MLA helpdesk at email@example.com.
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.