Compliance Blog

Written by Steve Van Beek

We expect that both the adverse action notices and the risk-based pricing notices will be published in the Federal Register today.  We are not clairvoyant, but there is a process that allows you to see what will be included in the next day's Federal Register pages.  This is the "Public Inspection Desk."    

We will update this blog post when links to the Federal Register become available.  Update (7/15/2011):  

Regulation B (adverse action model forms) here.  

Regulation V (risk-based pricing notices) here.  

Note:  While both the amendments indicate they are effective in 30 days, the underlying requirements of Section 1100F from Dodd-Frank become effective on July 21, 2011.  Credit unions should do their best to get their notices updated and ready for July 21, 2011.

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NCUA has posted the agenda for its July Board Meeting.  On the rulemaking side, there are three items of interest:

1. Final Rule – Parts 700, 701, 702, and 741 of NCUA’s Rules and Regulations, Net Worth and Equity Ratio Definitions.
2. Interim Final Rule – Section 701.30 of NCUA’s Rules and Regulations, Remittance Transfers.
3. Proposed Rule – Part 712 of NCUA’s Rules and Regulations, Credit Union Service Organizations (CUSOs).

The text of these proposals and final rules will be available on the morning of the Board meeting - a familiar date - July 21, 2011.  

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The Federal Trade Commission announced a new CAN-SPAM education tool for small businesses.  The new video discusses "seven things you need to know to comply with CAN-SPAM."  There is also a useful transcript of the video at the bottom of the page.