Compliance Blog

Written by Elizabeth M. Young LaBerge, Senior Regulatory Compliance Counsel

The compliance gauntlet that is 2017 is underway and compliance officers are running through it like it's the finals of American Ninja Warrior. NCUA has started off the year by issuing two Regulatory Alerts, both relating the CFPB regulations governing mortgages. It always helps to see the obstacle course beforehand.

Mortgage Servicing and the FDCPA

In Regulatory Alert No. 17-RA-01, NCUA highlights the CFPB's recent amendments to the 2013 Mortgage Servicing Rules and the Interpretive Rule issued by the CFPB regarding the amendments in light of the FDCPA. The alert is intended to provide general information about the CFPB's rules, and outlines some very high level changes. Credit unions looking for more in-depth information about these rules can review NAFCU's 2016 Mortgage Servicing Rules & TRID Compliance webpage.

HMDA Data Collection

In Regulatory Alert No. 17-RA-02, NCUA provided a summary of HMDA's institutional coverage for data collection in 2017:

Regulation C requires you to collect HMDA data associated with mortgage loan applications processed during 2017, if:

1. Your credit union's total assets as of December 31, 2016, exceeded $44 million;²
2. Your credit union had a home or branch office in a Metropolitan Statistical Area on December 31, 2016;
3. Your credit union originated at least one home purchase loan (other than temporary financing such as a construction loan) or refinanced a home purchase loan, secured by a first lien on a one-to-four-family dwelling during 2016; and
4. Your credit union originated at least 25 home purchase loans, including refinancings of home purchase loans in each of the two preceding calendar years (2015 and 2016).³

If your credit union meets all four criteria, you must collect HMDA data during calendar year 2017 and submit the data to the Consumer Financial Protection Bureau no later than March 1, 2018.

If your credit union does not meet all four criteria, you are exempt from filing HMDA data for calendar year 2017.

Credit unions looking for more in-depth information about the new HMDA rules, their institutional or transactional coverage, or the timelines for implementation, can visit NAFCU's HMDA Compliance webpage.

Consumer Compliance Regulatory Update Webinar

Compliance officers looking for more information on recent regulatory changes can sign up for the Federal Reserve's Consumer Compliance Regulatory Update webinar. The webinar will be held Thursday, February 2 at 2:00 pm eastern. It's a great resource for compliance officers wanting to get ahead of the compliance crucible that will be the 4^th quarter of 2017. Registration for the webcast is here.

Regulatory Compliance School

Lastly, if you feel like you need a bootcamp before tackling this year's compliance gauntlet, join us at NAFCU's Regulatory Compliance School. Our spring school in the Washington, DC metro area is quickly approaching. Get up to speed by taking exams and earning the NCCO designation. If you are already an NCCO, earn the 24 hours you need for recertification and get your warrior face on so you can attack the implementation challenges of this upcoming year.

Enjoy $200 in savings with the code SPRINGSAVINGS if you register by February 10, 2017. Seats are filling up quickly, so check out the agenda and make your plans soon.