Compliance Blog

Posted by Anthony Demangone

Yesterday, I wrote about how Ms. Petraeus wrote a letter to America's largest lenders regarding the SCRA.  Earlier this week, Ms. Petraeus testified before the House Veterans Affairs Committee. The CFPB wrote about her testimony here, and you can access a copy of her remarks through that link. She educated the Committee on her role at the CFPB, as well as the role of the office she leads.

Within the CFPB, our job is to make sure that every division of the CFPB understands the unique military community and the financial issues that impact it. I plan to work with our examiners to ensure they are current on military-specific issues, to encourage our enforcement team to take action against financial providers who break the law to harm servicemembers and to work with the consumer response unit to be sure that it is attuned to the military community and responsive to its concerns. We also plan to work closely with the consumer financial education team at the CFPB. History has shown us that best practices developed in support of the military can translate to the larger US community – and that the military can be a great test bed for innovative financial education products that could have an application to the population at large.

Her testimony is a good reminder for me to repeat something I mentioned before.  The existence of her office within the CFPB will shine a light on the intersection of servicemembers and financial services.  The SCRA will receive more attention. The DoD "MAPR" regulations will receive more attention.  Servicemembers now have a visible champion on the Hill, and those who feel aggrieved have a place to voice their complaint.

All of this means that American financial institutions must understand the rules that apply when they deal with servicemembers and their families.  With that in mind, here are some familiar, but important, resources.

• The FFIEC issued detailed examiner procedures regarding the DoD regulations.
• NCUA issued Letter to Credit Union 09-CU-12, which contains not only the DoD procedures from the first link, but also procedures regarding the SCRA.
• Here's a 146-page overview of the SCRA. (Courtesy of the American Bar Association.)  This loads very, very slowly.
• Here's an SCRA guide published by a retired Army Reserve JAG colonel.  (Courtesy of the American Bar Association.) It is very detailed, and very handy.

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NAFCU will host its Member Call-In next Tuesday.  Sign up here.  It is a great member benefit, touching on all the major issues in CU-land.  But just what will we yabba-dabba about for an hour?  Well, we'll talk about the following:

• NAFCU's CEO, Fred Becker always kicks off the show with general comments about issues facing our industry.
• Next, our Legislative and Political Affairs teams will brief the listeners. They'll touch on interchange, Dodd-Frank technical corrections, GSE reform, tax reform and the federal budget, the MBL issue, and supplemental capital.
• Then our Regulatory Affairs team will discuss the corporate credit union situation, NCUA's new corporate rule, 2011 assessments, corporate stabilization, Dodd-Frank and the CFPB, incentive-based compensation, concentration and interest rate risk, changes to NCUA’s investment rule,  NCUA merger partner registry, the delay of the FASB fair value proposal, TDRs, and the consumer protection office at NCUA.
• I'm up next, addressing the Fed's recent decision to cease three Reg Z rulemaking efforts, NCUA's fiduciary duties rule, the SAFE Act registry,  Reg-Flex changes, insurance changes to non-interest-bearing transaction accounts, the SCRA, and consumer complaints.
• Finally, Dr. Tun Wai will analyze the economy and credit union trends. 

As I noted above, this is a member-only benefit. Not a member?  We'd love to have you join!  Shoot me an email if your credit union would like to learn more about becoming a NAFCU member.

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Have a great weekend, everyone!