Compliance Blog

 Posted by Anthony Demangone

Happy Monday, folks.  Thanks for the wonderful emails about baseball, and I apologize for any of you who took my April Fool's Day joke too seriously.  In any event, I welcome any and all feedback from y'all.  Don't hesitate to reach out.

Here's a few nuggets to start your week. 

Mortgage Loan Origination Compensation Rule Delayed.  Reportedly, the National Association of Mortgage Brokers (NAMB) was successful in having the Federal Reserve's mortgage loan originator compensation rules delayed. In short, the U.S. Court of Appeals for the District of Columbia granted a stay that delays the implementation of this rule.  I wouldn't read more into this than what it is.  The court has basically said that NAMB has met enough of a burden for the court to hear additional details.  The government will have a chance to reply, as well NAMB.  The rule is not thrown out or invalidated.  The court is just buying a bit of time to gather additional information before it makes a final decision.  I wouldn't go dancing in the streets.  Stay tuned.

Interchange. You may want to share this website with your members: www.saveyourdebitcard.com.  The website makes it very, very easy for folks that are concerned with the Durbin Amendment to contact their Members of Congress about the issue.  And just in case you missed it, Mr. Bernanke indicated that the Fed will miss the April 21 deadline by which it had to get out a final debit interchange rule. 

Consumer Compliance Outlook.  The newest issue is out.  There's on article I'd like you to read, especially if your credit union does mortgage lending.  Under MDIA, when might you have to give corrected disclosures for an overstated APR?  Read this article. 

Commercial Real Estate Fraud.  FinCEN has released this advisory which alerts readers to possible signs of commercial real estate fraud.   The advisory also gives tips on SAR filings related to this.  The new acronym of the day? CREF. If your credit union does commercial real estate lending, you simply must read this.

***

Policies and Procedures for Credit Unions
Use promo code NAFCU11 to save 10%!