Compliance Blog

Posted by Anthony Demangone

My head is still spinning from last week.  Here's a little of this, and a little of that.  

• Note that on Thusday, the Fed issued a final rule to amend Regulation DD.  That's the bank version of Truth in Savings.  The changes take affect January 1, 2010, and they address overdraft protection programs.  NCUA has its own Truth in Savings reg, and I fully expect NCUA to follow suit quickly.  Here's a link to the final Reg DD rule.  What will it do?   It will require all depository institutions to disclose aggregate overdraft fees on periodic statements, and not solely institutions that promote the payment of overdrafts. The final rule also addresses balance disclosures provided to consumers through automated systems.
• NCUA has extended the CU Harp Deadline to December 29, 2008.  I thought the original deadline seemed a bit rushed.  I guess someone else agreed with me.

• On Thursday, the Fed announced its annual asset size bump for Reg C (HMDA.)  Credit unions with assets of $39 million or less as of December 31, 2008, are exempt from collecting data in 2009.

• The FDIC released the Winter 2008 issue of Supervisory Insights.   This is good reading.  This issue talks aobut liquidity risk (timely, eh?), reverse mortgages, and a discussion of "unfair and dececptive acts and practices." 

• NCUA issued Letter to Credit Unions 08-CU-25.  The guidance addresses holding foreclosed properties as Foreclosed and Repossessed Assets.  (Unfortunately, this is timely as well.) 

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Download Holiday Recipes!  The previous link takes you to the first annual, NAFCU Holiday Treats and Assorted Diet Busters Compliance Guide.  Enjoy, enjoy!  And many thanks for those who shared their wonderful recipes.