Compliance Blog

By Eliott C. Ponte, Law Clerk

No-Action Letters

Last month, the CFPB announced that it was proposing a policy for issuing no-action letters to institutions that want to be innovators.  Under the proposed regulation/policy, the CFPB staff, in its discretion, “would issue no-action letters to specific applicants in instances involving innovative financial products or services that promise ‘substantial’ consumer benefit where there is ‘substantial’ uncertainty whether or how specific provisions of statues or regulations implemented by the CFPB would be applied.”

The no-action letter issued by the CFPB would advise the recipient that, subject to its stated limitations, the CFPB has “no present intention to recommend initiation of an enforcement or supervisory action against the requester with respect to a specified matter.”  Thus, the no-action letter will give the institution the CFPB’s blessing to test their innovation as the institution saw fit.  

If you are interested in reading the Press Release from the CFPB, or the notice of the proposed rule in the Federal Register, click the links above. The CFPB is accepting comments until December 15, 2014.

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Final Lists of Rural and Rural or Underserved Counties For Use In 2015

Last week, the CFPB announced its final list of rural and rural or undeserved counties that credit unions and other lenders can use in 2015.  The lists are relevant to exemptions in several CFPB mortgage rules, including the CFPB’s rule requiring creditors to establish escrow accounts for certain first-lien higher-priced mortgage loans.  The list of the unserved and rural counties can be found on the right hand side of the CFPB’s website.

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NCUA Hosts Loan Portfolio Webinar

On November 19, 2014, at 2 P.M. est., the NCUA’s Office of Small Credit Union Initiatives will be hosting a webinar titled “Building a Loan Portfolio: Four Keys to Lending.”  The webinar will cover topics including: business planning, field of membership expansion and product mix; opportunities and challenges of serving the Hispanic market; growth through participation lending; and tips on vendor due diligence and NCUA compliance.

Registration for this webinar is available online here.  The NUCA has asked that credit unions submit questions in advance to WebinarQuestions@ncua.gov, with the subject line of the email as “Building a Loan Portfolio.”