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NAFCU, CFPB discuss CU operational challenges of stimulus checks
NAFCU Wednesday shared with the CFPB credit union concerns regarding the operational challenges posed by handling stimulus payment checks and potential regulatory relief the bureau could provide under Regulation CC. The Treasury Department began mailing physical checks to stimulus payment recipients this week.
During the discussion, NAFCU urged the bureau to encourage consumers to set up direct deposit using the IRS' Get My Payment portal. Through the portal, launched last week, individuals are able to provide their bank account information and track the status of their payment, including the date a payment is scheduled to be deposited or mailed.
NAFCU also highlighted that as an item distributed by the Treasury Department, stimulus payment checks may be subject to next-day availability under Regulation CC if deposited into an account held by the payee.
NAFCU Senior Regulatory Compliance Counsel Jennifer Aguilar discussed issues credit unions could face when processing stimulus checks, including funds availability under Regulation CC, in a recent post on the Compliance Blog.
"For funds availability, the clock starts ticking when the funds are deposited," noted Aguilar. "Under section 229.19(a), funds deposited in a branch or on-premises ATM are considered deposited when received at the branch or ATM."
"This may require credit union staff to ensure they are removing deposits from on-premises ATMs on a regular basis to meet any next-day availability requirements," she added.
A previous edition of NAFCU's Compliance Monitor also details how credit union operations could be affected by changes made by the Federal Reserve and CFPB to Regulation CC last year.