Compliance

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 …

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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 …

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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 …

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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 …

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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 …

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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 …

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CFPB Issues SSO Rules for Open Banking

The Consumer Financial Protection Bureau (CFPB) finalized in part its proposed rule on consumer financial data rights under Section 1033 of the Consumer Financial Protection Act (aka Title X of the Dodd-Frank Act of 2010). This final rule establishes minimum attributes a standard-setting organization (SSO) must possess to receive CFPB recognition and to issue consensus …

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