Legal Opinion Letters; Reg Z Closed-End and HELOC Proposal
Posted by Sarah Loats
It's Friday so how about we take a break from the Credit CARD Act and look at a couple of NCUA's recent LOL postings.
NCUA issued Legal Opinion Letter 09-0621 regarding the requirements to advertise abandoned property under the fixed assets rule. The rule requires a federal credit union to publicly advertise for sale property that has been abandoned for four years. This letter discusses whether listing the property with a real estate agent satisfies this requirement. Read about it here.
Legal Opinion Letter 09-0547 discusses the Department of Labor reporting requirement for Labor Trusts. According to NCUA's opinion, a federal credit union is not a trust within the meaning of the DOL rule and need not provide financial information to a sponsor labor union. A good read for credit unions with sponsor labor unions.
Legal Opinion Letter 09-0511 reiterates the types of activities a federal credit union may engage in in relation to investment advice services.
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Ugh, the Federal Reserve sure is busy! They just released the proposed amendments for HELOCs and closed-end loans. They've provided a 120 day comment period. Here's one interesting snippet from the press release that caught my attention:
The Board will also work with the Department of Housing and Urban Development to make the disclosures mandated by TILA, and HUD's disclosures, required by the Real Estate Settlement Procedures Act, complementary; potentially developing a single disclosure form that creditors could use to satisfy both laws.
That's if for today. Have a great weekend everyone!