Compliance Blog

Written by Steve Van Beek

Yesterday was NAFCU's 20th annual visit to the Federal Reserve to discussed credit union issues.  As part of the meeting, NAFCU prepared its 2012 NAFCU Report on Credit Unions.  I encourage you all to take a look and, perhaps, use it for your own Board briefings or management meetings.  For example, the Report includes the following on Reg D:

"Regulation D

An ongoing concern for NAFCU and its members is the outdated restriction on “convenience transfers” under Regulation D. The current law is burdensome and confusing for depositors that wish to have unfettered access to their funds. It is unreasonable to expect consumers to understand and remember the arcane limits on the number and type of transfers that are allowed from their savings account. The rule is outdated, and as a consequence, the restrictions on transfers are incoherent to even the most knowledgeable consumers. It would be helpful to consumers if the regulation was modified to reflect the current financial services environment.

In an electronic era where consumers demand the ability to transfer funds easily to and from particular accounts, the arbitrary limitation on six transfers from a savings account creates an undue burden for consumers and financial institutions alike. NAFCU believes that the six transfer limitation could be increased and still maintain a distinction between savings and transaction accounts. NAFCU strongly supports increasing the limit to at least nine convenience transfers per month."  [Page 16]

The Regulatory Issues Facing Credit Unions section begins on Page 15 of the Report and also includes sections on Debit Card Interchange Fees; the CFPB; Remittances; TILA/RESPA Integration; HOEPA loans; MLO compensation; Mortgage Servicing; Appraisals; Qualified Mortgages and plenty more.