Compliance Blog

Written by Brandy Bruyere, Regulatory Compliance Counsel

NCUA’s 2013 Annual Report

On May 12, 2014, NCUA released its 2013 Annual Report which highlights last year’s NCUA initiatives and accomplishments and the agency’s perceptions of its work on “easing regulatory burdens.” NCUA grouped its report into six broad categories, quoted from the agency’s press release:

• Implement an effective supervision program to ensure the continued safety and soundness of federally insured credit unions.
• Adopt safe, targeted and flexible regulations to protect the credit union system and maintain a strong and independent National Credit Union Share Insurance Fund.
• Modernize the agency’s operations.
• Minimize assessments for the Temporary Corporate Credit Union Stabilization Fund.
• Engage and provide assistance to key stakeholders.
• Serve as a responsible steward of the public’s trust.

The report also highlights an area of particular interest for those who work in compliance—fair lending exams. In 2013, NCUA’s Division of Consumer Compliance Policy and Outreach examined 26 credit unions for compliance with fair lending laws. This exceeded NCUA’s annual goal to conduct 18 on-site fair lending examinations by 44% and the exams took NCUA 5,334 hours to complete. For those keeping score at home, that’s over 205 hours per examined credit union. NCUA more than doubled the number of such exams compared to 2012, when the agency conducted only 10 fair lending exams. Additionally, NCUA reported 41 off-site supervisory contacts with credit unions relating to fair lending compliance. The increased focus on fair lending supervision serves as a reminder that while following new regulations is important, so are long standing provisions under rules like Regulation B (ECOA) and Regulation C (HMDA). For those who are interested, NCUA has a collection of fair lending compliance resources including its Fair Lending Guide.

NCUA Board Meetings—Agenda for May and Video Available for April

On May 15^th, NCUA released its agenda for this month’s Board meeting. May’s agenda is not particularly exciting, which is probably a good thing since “exciting” when used to describe a Board meeting is too often a euphemism for “more regulations.” Here are the three items on the agenda:

• Notice and Request for Comment, Economic Growth and Regulatory Paperwork Reduction Act Review (EGRPRA);
• AERO Federal Credit Union (Glendale, AZ) Request to Ad Two Underserved Areas;
• Corporate Stabilization Fund Quarterly Overview.

The first item is worth noting because under the EGRPRA, NCUA is required every ten years to invite comment on rules that are outdated, unnecessary, or unduly burdensome. This is a good opportunity to stress the need for regulatory relief in important areas so credit unions may want to consider participating in this public comment process.

Finally, for those who are interested, on May 15^th NCUA also uploaded the video for April’s Board meeting to its website. Just as a reminder, the April meeting included a proposed rule on associational common bond requirements and a final rule on capital planning and stress testing.

Webcast: Advertising Series--Truth in Savings and Its Impact on Social Media

Social media is a powerful advertising tool…and a dangerous one. Understand social media advertising risks regarding Truth in Savings with this helpful compliance webcast. You’ll examine advertising requirements such as trigger terms, APY disclosures and electronic promotions. Plus, you’ll dive FFIEC’s final guidance on social media, and get best practices for managing advertising and social media compliance at your credit union. Register by June 11 to save $100.

Nanny Dog

My husband and I recently babysat for some friends, and like many babies, our friends’ son was a little upset at bedtime. Lemmy just couldn’t stand to hear the baby cry, so he “helped” get the little guy to go to sleep.