Compliance Blog

Happy Friday, everyone.  Here are a few things before we hit the weekend.

Recently, Steve Van Beek wrote about how a provision in the healthcare overhaul law will require additional 1099-MISC filings by many American businesses, credit unions included.  Efforts have already begun to try to overturn that provision.  (Source: Politico.) They have been unsuccessful so far, but this issue appears to be in play.  Stay tuned. 

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I'm currently in chilly San Francisco, attending the Annual ABA Conference.  No, not that ABA.  I'm at the American Bar Association annual meeting.  The ABA has a number of credit union subcommittees.  That's where I'll be spending my time, hoping to learn as much as I can from fellow credit union attorneys.  I'll share as much information from the meetings as I can in the coming weeks. 

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As we've stated before, Steve Van Beek and I will deliver a series of shot-gun style compliance overviews during October's NAFCU Regulatory Compliance Seminar.  These sessions will allow us to address things that have come up after we secured speakers and topics.  The goal is to make sure that you'll get a taste of these things before you head home.  So far, here is what we have.  Do you have something you want us to add?  Email us, if you do.  Also, keep in mind that the early-bird registration deadline is August 20.  You can learn more about the Seminar via the link above. 

1.      Dodd-Frank
 a.       Interchange
 b.      CFPB
 c.       Mortgage Reform
 d.      Miscellaneous

2.      Material loss reviews

3.      NCUA’s new stance on administrative actions

4.      NCUA fiduciary duties proposal/final

5.      Letters to Credit Unions (of note)
 a.       10-CU-02 (Current Risks in Business Lending)
 b.      10-CU-03 Concentration Risk
 c.       10-CU-06 – Interest Rate Risk
 d.      10-CU-07 – Commercial Real Estate Workouts
 e.       10-CU-08 – NFIP Lapses
 f.        10-CU-10 – BCP (pandemic and hurricanes)
 g.       10-CU-11 – NCUA Merger and P and A Process
 h.       09-CU-23 – Adequacy of earnings

6.      Legal Opinion Letters
 a.       10-0214 “Floor” Rates on HELOCs.
 b.      09-1229 – Compliance CUSOs
 c.       09-1067 – HSAs and share insurance
 d.      09-1039 – BOD Conflicts, disqualifications and voting majorities

7.      ADA and ATMs

8.      Health Care Reform and 1099-MISCs

9.      Regulation E Aftermath

10.  Reg Z Closed End?

11.  BSA Update

12.  Privacy

13.  Reg GG Update

14.  Risk-based pricing

15.  CARD Act: APR Reviews (upcoming, first deadline)