Compliance Blog

Here's something I wanted to bring to your attention concerning address discrepancies and share accounts.   Under the new FACT Act rules, does a credit union have to report a correct address back to the CRA when it pulls a credit report in relation to a share account? This is a question we’ve received a bunch lately. The regulation does not appear to make a distinction between share and loan accounts, but CRAs are informing credit unions that the requirement to report a confirmed address only kicks in when the credit union has a loan product with the consumer. We decided to check with NCUA to see if they knew about the situation.  As it turns out, not only is NCUA aware of the confusion, but so is the entire FFIEC interagency group. In fact, they will soon be discussing this issue amongst themselves. No word yet as to how it will all pan out, but somehow it’s nice to know they are aware the issue exists.  Stay tuned.

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Yesterday's NCUA Board meeting was a busy one.  You can access all the final regs and board reports here.  And you can read Boardmember Gigi Hyland's statement about the meeting here.

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OK, you may notice that the Compliance Guy is not known as the Skinny Compliance Guy.  I have a sweet tooth that is as large as the Bank Secrecy Act is annoying.  With that in mind, I thought of a new holiday-idea for the blog.  Send in your favorite family "dessert" recipe.  It could be for cookies, brownies, egg-nog, buckeyes (my grandmother's specialty) or some other delectable, sweet concoction.  Send your recipes to compliance@nafcu.org, and we'll put them to make the first annual "NAFCU Compliance Blog Holiday Recipe Guidance Document."  Please get your recipe to us by December 12.  We'll get the cookbook out by the following Tuesday.

Want an example?  Seamus, one of my colleagues, brought a batch of these peanut butter cup brownies into the office a few weeks ago.  They were so good, a fight almost broke out over the last one.

Peanut Butter Cup Brownies.

1- cup crunchy peanut butter
1- 1 lb. box 10x sugar
1 ½  cups of graham cracker crumbs (crush in ziploc bag)
1 cup butter soften
1- 12 oz bag of chocolate chips

Mix first four ingredients together.
Spread mixture by hand into 9x13 pan. 
Melt 12 oz bag of chocolate chips slowly.
Spread on mixture. Chill and cut into 1"x 1" squares.     

Editor's Note: 10X refers to the number of times the sugar is processed to produce fine powder. Powdered sugar, 10X sugar, confectioner's sugar (0.060 mm), or icing sugar (0.024 mm) are equivalent to one another.

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Have a great weekend, everyone