Compliance Blog

Yesterday, NCUA released Letter to Credit Union 08-CU-23.  The letter urges credit unions to consider the Central Liquidity Facility should they need help meeting their liquidity needs.  Need more info on the CLF after you read the letter?  Visit NCUA's Central Liquidity Facility homepage.  It is chock full of good information. 

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Yesterday, the Fed issued a final regulation to amend Regulation C.    The changes put into effect changes regarding higher priced mortgage loans.  Read all about it here.

Regulation C currently requires lenders to collect and report the spread between the annual percentage rate (APR) on a mortgage loan and the yield on a Treasury security of comparable maturity if the spread is greater than 3.0 percentage points for a first lien loan or greater than 5.0 percentage points for a subordinate lien loan.  This difference is known as a rate spread. Under the final rule, a lender will report the spread between the loan's APR and a survey-based estimate of APRs currently offered on prime mortgages of a comparable type ("average prime offer rate") if the spread is equal to or greater than 1.5 percentage points for a first lien loan or equal to or greater than 3.5 percentage points for a subordinate-lien loan.  The Board will publish average prime offer rates based on the Primary Mortgage Market Survey® currently published by Freddie Mac.  The Board will conduct its own survey if it becomes appropriate or necessary to do so.

The changes take effect October 1, 2009.