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New on the Compliance Blog: CFPB ‘junk fees’ guidance, physical address questions
As credit unions work to meet the needs of more than 134 million Americans, NAFCU's award-winning regulatory compliance team continues to keep credit unions informed with new posts on the Compliance Blog, published every Monday and Wednesday.
Here's a roundup of what's new this week:
What is Going On? CFPB Releases Guidance on “Junk” Fees: Regulatory Compliance Counsel Justin White discusses the CFPB’s recently released guidance on “junk fees.” The post explains the bureau's guidance on surprise overdraft fees, which the CFPB labels as “when financial institutions assess overdraft fees on transactions that a consumer would not reasonably expect.” Additionally, White highlights that the CFPB noted that fees charged for a Returned Deposited Item are “likely unfair.”
When Members Won’t Talk: Obtaining a Physical Address: Senior Regulatory Compliance Counsel Rebecca Tetreau explains the complications of pulling credit reports to obtain a physical address for noncooperative members. Tetreau notes a section of FinCEN’s regulations requires a physical address to open an account, but the regulation does not address obtaining subsequent physical addresses. However, Article XVI, Section 7 of NCUA’s current Model Bylaws says that members must inform the credit union of their mailing address, so even a P.O. Box appears to satisfy this requirement. This means that there is a lack of explicit regulatory requirements for obtaining subsequent physical addresses when members request to update their mailing address to a P.O. Box.
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