Does your credit union offer loans? If so, have you looked at your underwriting requirements recently? Specifically, what weight does the credit union give an applicant’s citizenship status? The Equal Credit Opportunity Act (ECOA) and Regulation B, section 1002.2(z) prohibits discrimination based on national origin. However, under section 1002.6(b)(7): “A creditor may consider the applicant’s …
On March 27, 2024, the Consumer Financial Protection Bureau (CFPB) released Consumer Financial Protection Circular 2024-02 (the circular). The circular discusses the Consumer Financial Protection Act’s (CFPA) prohibition on deceptive acts or practices when marketing the cost and/or speed of sending remittance transfers. To those unfamiliar with deceptive acts or practices, under the CFPA, a …
CFPB Releases Circular on Deceptively Marketing Remittance Transfers Read More »
It’s that time of the year again, the HMDA reporting deadline! As noted in this NCUA Letter to Credit Unions, the deadline to report 2023 HMDA data to the CFPB is March 1, 2024. What about for 2024 data? Well fortunately, the 2023 HMDA letter is not an anomaly and NCUA generally publishes an annual …
Happy January 18th everyone. It’s national Michigan day! Fun fact about America’s Credit Unions’ compliance team, one third of our team members live in Michigan. Did you know, people who live in Michigan are called Michiganders. Did you also know that on January 12, 2024, FinCEN released an updated Paycheck Protection Plan (PPP) FAQ? Specifically, …
FinCEN Updates PPP FAQ Clarifying Permission to Acknowledge Filing of a SAR to SBA Read More »
