Compliance Blog

Written by Shari R. Pogach, Regulatory Paralegal 

Consumer Compliance Outlook. The First Quarter 2015 issue of the Federal Reserve’s Consumer Compliance Outlook is now available. Articles of interest in this issue include: 

• Consumer Compliance Requirements for Commercial Products and Services
• The Expanded Scope of High-Cost Mortgages Under the Dodd-Frank Wall Street Reform and Consumer Protection Act
• Agencies Issue Guidance on Youth Savings Program
• Compliance Spotlight: Waiting Period for MPPP Lender Force-Placed Flood Insurance

Though referred to as “federal consumer protection laws,” it is important to remember that some of the federal consumer protection laws and corresponding implementing regulations are not limited to consumer products and services. For example, the Equal Credit Opportunity Act/Regulation B, the Flood Disaster Protection Act and the Servicemembers Civil Relief Act, among others, also apply to commercial products and services.  And, although generally limited in scope to consumer products and services, other consumer protection laws have certain provisions that also apply to commercial products and services.  For example, Regulation Z has certain requirements for business-purpose credit cards. 

The compliance requirements of these federal consumer protection laws should be reviewed and integrated into a credit union’s applicable policies and procedures to ensure compliance when offering commercial products and services.  A good starting point is this general overview provided in the First Quarter 2015 issue. 

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NAFCU Webcast.   Be sure to join us for NAFCU’s Regulatory Compliance Update with JiJi Bahhur and the Compliance Team on Thursday, May 14, from 2:00 -3:30pm ET.  Our highly-anticipated Compliance Update is back! NAFCU’s Regulatory Compliance team will explore recent Consumer Financial Protection Bureau (CFPB) and National Credit Union Administration (NCUA) rules, regulations and guidance, plus discuss how the upcoming changes and proposals could affect your credit union. Definitely plan on attending this enlightening webcast to help ensure your credit union’s compliance efforts are up-to-date.