New Compliance Blog posts tackle contracts, CD versus share certificates 

America’s Credit Unions keeps credit unions informed with new posts on the Compliance Blog, published every Tuesday and Thursday. 

Here’s a look at what’s new on the blog: 

Are Unlawful Terms in Your Contract a Deceptive Act or Practice?: Keith Schostag breaks down the CFPB’s June 4 circular that specifies having unlawful or unenforceable terms and conditions can be a violation of the Consumer Financial Protection Act’s (CFPA) prohibition on deceptive acts or practices. Schostag provided various examples of unenforceable terms in contracts and recommended credit unions review their contracts to ensure compliance. 

Share Certificate or CD?: Tara Simpson noted that NCUA regulations do not allow credit unions to call share certificates a deposit account. Section 707.2(a) of the NCUA’s Truth in Savings rule explicitly states “the term ‘certificate of deposit’ or ‘CD’ may not be used to describe share certificates and other dividend-bearing term share accounts.” However, Simpson pointed out that state-chartered credit unions may offer both share and deposit accounts if permitted by state law. 

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