Compliance

COPPA, and Not “The Copa”

The Children’s Online Privacy Protection Act (COPPA) is the topic of the day, and not the Italian word for “cup” or the famous nightclub in NYC that was the topic of the late seventies’ song by Barry Manilow. Now that summer is in full swing, I was listening to Yacht Rock radio (as I always …

COPPA, and Not “The Copa” Read More »

FCU Account or Signature Card

Unlike the last five years’ worth of my birthday cards, account cards give members access to money. Also, unlike my birthday cards, it really matters what words are written on member account cards. Unlike my family… hopefully, his family was kind enough to reward him just for being born. From time to time, credit unions …

FCU Account or Signature Card Read More »

What’s an “Investment Advice Fiduciary”?

This past April, the U.S. Department of Labor (DOL) published a final rule re-defining when a person is an “investment advice fiduciary” for purposes of the Employee Retirement Income Security Act (ERISA). ERISA governs workplace employee benefit plans, such as pension plans and 401(k) plans, along with other types of retirement savings plans, such as …

What’s an “Investment Advice Fiduciary”? Read More »

Same Currency Transaction Report (CTR)?

We frequently receive compliance questions regarding various issues related to currency transaction reports (CTRs). However, this blog is going to address one of the scenarios I’ve been presented with recently. The question I received was regarding whether a withdrawal and a deposit can be included on the same CTR. So, what does the applicable guidance …

Same Currency Transaction Report (CTR)? Read More »

CFPB Enforcement Action Highlights Consequences of HMDA Errors

On June 18, 2024, the Consumer Financial Protection Bureau (CFPB) filed a stipulated final judgment against Freedom Mortgage Corporation (Freedom) for alleged violations of the Home Mortgage Disclosure Act (HMDA), Regulation C, and the Consumer Financial Protection Act. Financial institutions, including credit unions, are required to comply with HMDA and Regulation C if they meet …

CFPB Enforcement Action Highlights Consequences of HMDA Errors Read More »

NCUA and Other Agencies Issue Final Rule on QC Standards for AVMs

The National Credit Union Administration (NCUA), Office of the Comptroller of the Currency, Treasury (OCC), Board of Governors of the Federal Reserve System (Fed), Federal Deposit Insurance Corporation (FDIC), Consumer Financial Protection Bureau (CFPB), and Federal Housing Finance Agency (FHFA) (collectively, the agencies) have adopted a final rule to implement the quality control standards mandated …

NCUA and Other Agencies Issue Final Rule on QC Standards for AVMs Read More »

Junk Fees and Residential Mortgage Transactions

In May 2023, the CFPB released a special edition of its Supervisory Highlights that reported on the unlawful junk fees including those in the mortgage servicing marketplace as well as other areas such as bank accounts, student loans, and auto loans.  The junk fees the CFPB discovered in the mortgage servicing arena included charging excessive …

Junk Fees and Residential Mortgage Transactions Read More »

Scroll to Top