Remote Deposit Capture; RESPA
Yesterday, NCUA released NCUA Letter to Credit Union 09-CU-01. Here's a link to the letter, and its attachment. The attachment is a risk-management gidance document from the FFIEC. For a credit union that is looking to enter into this arena, or even for those who already offer remote deposit capture, these guidance documents are a must read.
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We keep hearing that HUD is delaying enforcement of the RESPA provisions that were to become effective on January 16, 2009. Granted, there's nothing on HUD's website that states this. But it is apparent that the delay will take place. HUD spokesman Brian Sullivan is quoted to have said the following in this article.
"We could have argued the preliminary injunction," Sullivan told HousingWire. "What weâÂÂve done is, instead of contesting a preliminary injunction, we decided that we would simply agree to delay the implementation of the new âÂÂrequired useâ provision for 90 days while we could produce the administrative record and get our legal ducks in a row to mount a vigorous defense of our position on the merits of the case."
In any event, if you are interested in a detailed explanation of the three parts of the RESPA rule that will take effect (either on January 16 or April 16, 2009), download and read this document. (NAFCU Members only, log-in needed.)