Compliance Blog

Written by Steve Van Beek

Quite a few compliance issues going on besides the credit score disclosures.

RESPA.  HUD finalized a technical corrections rule that clarifies some RESPA issues.  These clarifications reiterate HUD's positions on a couple of issues - such as a borrower's intent to proceed with a loan - and become effective August 10, 2011.  While the clarifications do not make substantial changes to RESPA, this might be a good time to review your credit union's procedures to ensure they are in line with HUD's clarifications.  My suspicions are that HUD wanted to get these clarifications out before RESPA transferred to the CFPB on July 21, 2011.    

Online Member Authentication Guidance.  NCUA issued Letter to Credit Unions 11-CU-09 to inform credit unions of the new online authentication guidance issued by the Federal Financial Institutions Examination Council (FFIEC).  This updated guidance is a supplement to the 2005 guidance (Letter to Credit Unions 05-CU-18).

We took a quick look at this guidance late last month and will have more coming up in our next NAFCU Compliance Monitor.  

NAFCU Finals and Regulatory Alerts.  Our regulatory affairs team has been busy keeping up with the latest proposed and finalized rule.  NAFCU recently released the following:

• Regulatory Alert on NCUA's Advanced Notice of Proposed Rulemaking (ANPR) on Derivatives;
• Regulatory Alert on the Interim Final Rule on Interchange Fraud Adjustments; and
• Final Regulation on the Debit Interchange Final Rule on Fees and Network Routing.  

NAFCU members can access the Regulatory Alerts here and the Final Regulations here.