Compliance Blog

Written by Steve Van Beek

On Tuesday, the CFPB issued a press release outlining its approach for supervising depository institutions over $10 billion in assets.  For more information on the CFPB's approach, see Wednesday's NAFCU Today story.

One thing that caught my eye as a compliance junkie?  This part at the very bottom:

"The CFPB will post on its website the initial phase of its Examination Manual, which is the field guide for examiners supervising both banks and other consumer financial services companies. The publication of the manual will be accompanied by a general invitation for feedback and suggestions for improvements from the banking industry, nonbank financial services companies, federal and state agencies, consumer and community groups, and the general public." 

If done right, this manual could be a great resource for all credit unions regardless of asset size.  It will also be useful in a situation where your NCUA examiner has a different opinion on an issue than your credit union.  Remember, after July 21, 2011, the CFPB becomes the authority on all consumer regulations.  In the past, NCUA would look to the Federal Reserve on Reg E or Reg Z issues but going forward this is the CFPB's territory.  Hopefully the CFPB will use plain English in its manual and not just recite the regulatory language (a habit other regulators have, unfortunately, fallen into).  

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We have touched on ATM fee disclosures in a couple of blog posts already in 2011 - here; here and here.  As I was researching another issue yesterday, I ran across an article from NCUA's Office of Consumer Protection on this issue as well.  The article provides a straightforward overview of the disclosure requirements and can be found on page 5 of the May 2011 NCUA Report.