Compliance Blog

Written by Bernadette Clair, Regulatory Compliance Counsel

I thought we’d keep it light today and tomorrow and highlight a few housekeeping changes credit unions need to check off by January 1, 2013.

With the CFPB’s republishing of Regulation B in 12 CFR 1002, Regulation V in 12 CFR 1022, and Regulation Z in 12 CFR 1026, a few forms need to be updated with current agency contact information.  We’ve blogged on some of these before, but thought it would be helpful to have them all in one place.

Risk-Based Pricing Notices.  The CFPB’s republishing of Regulation V into 12 CFR 1022 included updates to model forms in several Appendices, including the risk-based pricing notices in Appendix H.  For example, Model form H-1 now reflects the CFPB’s website address:

“For more information about credit reports and your rights under Federal law, visit the Consumer Financial Protection Bureau's website at www.consumerfinance.gov/learnmore.”

Adverse Action Notices.  The CFPB's republishing of Regulation B into 12 CFR 1002 updated Appendix A to reflect the new address for NCUA's Office of Consumer Protection (OCP).  The CFPB's Appendix A now includes the following (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." 

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

We blogged in depth about this update to the adverse action notice on January 13, 2012. 

We'll continue looking additional changes tomorrow.