Compliance Blog

Written by Michael Coleman, Regulatory Compliance Counsel

Regulation B - Adverse Action Notices

When the CFPB republished Regulation B into 12 CFR 1002, they updated Appendix A to Part 1002 to reflect the address for NCUA’s new Office of Consumer Protection (OCP), which is required to be listed on adverse action notices for credit unions under $10 billion in assets starting January 1, 2013.

The underlying requirement for including the agency address on adverse action notices comes from 12 CFR 1002.9(a)(2) and (b)(1).   

Appendix A to Part 1002  now includes this information for FCUs under $10 billion on assets:

"d. Federal Credit Unions: National Credit Union Administration, Office of Consumer Protection (OCP), Division of Consumer Compliance and Outreach (DCCO), 1775 Duke Street, Alexandria, VA 22314." 

Credit unions over $10 billion in assets need to include the CFPB's name and address:

“1. Banks, savings associations, and credit unions with total assets of over $10 billion and their affiliates: Bureau of Consumer Financial Protection, 1700 G Street NW., Washington DC 20006. Such affiliates that are not banks, savings associations, or credit unions also should list, in addition to the Bureau: FTC Regional Office for region in which the creditor operates or Federal Trade Commission, Equal Credit Opportunity, Washington, DC 20580.”

State-chartered credit unions should check the address on their notices and determine if it matches the FTC address in #9 from Appendix A. 

For additional details, check out this January 13, 2012 blog post

Regulation V - Risk-Based Pricing Notices

Regulation V was also updated when the CFPB republished Regulation V in 12 CFR 1022 and will require the CFPB's website address on risk-based pricing notices after January 1, 2013.  

The requirement comes from 12 CFR 1022.73(a)(1)(viii) which mandates that credit unions provide this on their risk-based pricing notices:

"(viii) A statement directing consumers to the Web site of the Bureau to obtain more information about consumer reports;"

After January 1, 2013 - credit unions need to make sure they have the updated language referencing the CFPB.  Appendix H to Part 1022 has the model forms where you can see the risk-based pricing notice requirements.  

For additional details, check out this June 7, 2012 blog post.

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Redskins – I am a huge Skins fan, and as anyone who is familiar with the trials and tribulations of being a sports fan in DC knows, it’s not easy being green (or burgundy and gold in this case). But I am one of those optimistic Redskins fans. The Skins have a shot at the playoffs this year, and have two huge games to close out the season (against the Eagles and then the Cowboys, fingers crossed). It’s not certain if Robert Griffin III will start this weekend, but even if he doesn’t, I’m optimistic that Captain Kirk will continue to perform. I also like to focus on the good things from the season. Like the fact that even when RG3 fumbles, we score touchdowns (sorry New York readers). Go Skins!