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Articles by Tara Simpson
Oral Consent for Regulation E Overdraft Opt-In
Happy Wednesday! I hope everyone had a great holiday! Here is a picture of my cat, Quincy, all snuggled up and enjoying the holiday season. Today’s blog is going to discuss members providing oral consent with respect to opting-in to receive overdraft coverage under Regulation E. In order to set the stage for this blog, I need to mention this CFPB Press Release which details the CFPB ordering Atlantic Union Bank “to pay $6.2 million for illegal overdraft fee harvesting”.
Customer Identification Program (CIP) requirements and non-U.S. persons
Happy early Thanksgiving! Amongst many other things, I am thankful that social media filters work on my cat, Quincy, so I can take fun holiday photos of him to share. This week, my blog is going to focus on Customer Identification Program (CIP) requirements and non-U.S. persons. I have been getting quite a few questions on this lately, so I thought a blog refresher may help.
Customer Identification Program (CIP) Requirements and Non-U.S. Persons
Nov 22, 2023 Categories: BSA Customer Identification Program (CIP) Requirements and Non-U.S. Persons Happy early Thanksgiving! Amongst many other things, I am thankful that social media filters work on my cat, Quincy, so I can take fun holiday photos of him to share. This week, my blog is going to focus on Customer Identification Program (CIP) requirements and non-U.S. persons. I have been getting quite a few questions on this lately, so I thought a blog refresher may help.
De minimis exception to submitting credit card agreements to the CFPB
Happy Monday! Tomorrow is Halloween and I am looking forward to going trick-or-treating with my niece and nephew. They are both so excited to dress up and get candy (and I may or may not also be excited to snag a piece from them here and there)! My compliance Halloween treat is a continuation of my last blog, which can be found here. In that blog, I wrote about submitting credit card agreements to the CFPB.
De Minimis Exception to Submitting Credit Card Agreements to the CFPB
Oct 30, 2023 Categories: Credit Cards CFPB De Minimis Exception to Submitting Credit Card Agreements to the CFPB Happy Monday! Tomorrow is Halloween and I am looking forward to going trick-or-treating with my niece and nephew. They are both so excited to dress up and get candy (and I may or may not also be excited to snag a piece from them here and there)! My compliance Halloween treat is a continuation of my last blog, which can be found here.
Submitting Credit Card Agreements to the CFPB
Happy Monday, Compliance Friends! I hope everyone had a great weekend and I hope that those who attended NAFCU’s 2023 Regulatory Compliance & BSA Seminar in Savannah, Georgia last week also had a great time. The topic of today’s blog is about submitting credit card agreements to the CFPB. I have received a few questions about this subject in the last few weeks, so I figured it’d be a good idea to provide a little refresher.
Providing Customer Notice under the Customer Identification Program (CIP) Rules
Sep 06, 2023 Categories: BSA Providing Customer Notice under the Customer Identification Program (CIP) Rules As part of compliance with the Bank Secrecy Act (BSA), credit unions are required to have a written Customer Identification Program (CIP), which should be designed so that the credit union can verify the identity of each “customer.” The Customer Identification Program (CIP) rules are found in section 748.2(b)(2) of the NCUA regulations and section 1020.220 of the FinCEN regulations.
On-Us Checks Deposited at a Proprietary ATM and Availability under Regulation CC
Aug 14, 2023 On-Us Checks Deposited at a Proprietary ATM and Availability under Regulation CC Happy Monday, compliance friends! I hope everyone had a nice, relaxing weekend. Before we get to the topic of this blog, here is a picture of my cat, Quincy, relaxing and not worrying about when my particular funds are going to be made available (all he knows is that he owns the place and I just pay the bills).
An Overview of the Reasonable Cause to Doubt Collectibility Exception under Regulation CC
Jul 17, 2023 An Overview of the Reasonable Cause to Doubt Collectibility Exception under Regulation CC Today’s blog is going to discuss the reasonable cause to doubt collectibility exception under Regulation CC. I’ve received quite a few questions on this in the past, so I thought it might be a good idea to go over this particular exception in more depth. First, just to provide a little background, section 229.13 outlines exceptions to the general availability schedules.
Adjustable-Rate Mortgages (ARMs) and Notice of the LIBOR Transition
Jun 14, 2023 Adjustable-Rate Mortgages (ARMs) and Notice of the LIBOR Transition The use of the LIBOR index is expected to end on June 30, 2023.
Flipped houses and second appraisals
So, you’ve been watching HGTV lately and thinking about flipped houses. It seems like everyone wants to get in on the craze of buying a house, making a few improvements to it, and then selling it for a huge profit. You begin to wonder; do all flipped houses require a second appraisal? Well, this Q&A from the CFPB provides that “[i]f the home you’re buying is considered a “flip” and you’re getting a higher-priced mortgage loan covered… you will have to get a second appraisal.” (Emphasis added).
Flipped Houses and Second Appraisals
So, you’ve been watching HGTV lately and thinking about flipped houses. It seems like everyone wants to get in on the craze of buying a house, making a few improvements to it, and then selling it for a huge profit. You begin to wonder; do all flipped houses require a second appraisal? Well, this Q&A from the CFPB provides that “[i]f the home you’re buying is considered a “flip" and you’re getting a higher-priced mortgage loan covered… you will have to get a second appraisal.” (Emphasis added).
Eligibility requirements to run for the board of directors
Happy Wednesday! Here is a little fun fact to start your day… today is National Garden Meditation Day! Since it is still the middle of the work week, it may help you to recharge by going out into your garden (or a public garden) and practicing some meditation. For inspiration, here is a picture of my cat, Quincy, meditating in front of a virtual tv garden.
Eligibility Requirements to Run for the Board of Directors
May 03, 2023 Eligibility Requirements to Run for the Board of Directors Happy Wednesday! Here is a little fun fact to start your day… today is National Garden Meditation Day! Since it is still the middle of the work week, it may help you to recharge by going out into your garden (or a public garden) and practicing some meditation. For inspiration, here is a picture of my cat, Quincy, meditating in front of a virtual tv garden.
Do emails containing transactional or relationship content require an unsubscribe option?
Happy Wednesday, Compliance Friends! Today, I’ll be discussing the Controlling the Assault of Non-Solicited Pornography and Marketing Act (the CAN-SPAM Act) and whether credit unions are required to provide an unsubscribe option in emails that contain transactional or relationship content. The prohibition against deceptive (i.e., the “source, destination, and routing information”) applies to all emails. However, other CAN-SPAM prohibitions and requirements only apply to commercial emails.
Do Emails Containing Transactional or Relationship Content Require an Unsubscribe Option?
Apr 19, 2023 Do Emails Containing Transactional or Relationship Content Require an Unsubscribe Option? Happy Wednesday, Compliance Friends! Today, I’ll be discussing the Controlling the Assault of Non-Solicited Pornography and Marketing Act (the CAN-SPAM Act) and whether credit unions are required to provide an unsubscribe option in emails that contain transactional or relationship content.
Can credit unions purchase participation loans?
Happy Wednesday, Compliance Friends! It was nice seeing some of you a couple weeks ago at Compliance School! Recently I’ve received a couple questions regarding participation loans, so I figured it would be a good idea to compose a blog on the topic. Section 701.22 of NCUA’s regulations discusses loan participations. Section 701.22(b) states: continue reading »
NCUA’s field of membership proposed rule and secondary members
Happy Monday, compliance friends! Today we’re going to talk about the National Credit Union Administration’s (NCUA) proposed rule regarding chartering and field of membership (FOM) regulations. Specifically, the portion dealing with the eligibility of immediate family members of decedents. Current Rule You can either be a primary or a secondary member of a credit union.
NCUA’s Field of Membership Proposed Rule and Secondary Members
Mar 06, 2023 NCUA’s Field of Membership Proposed Rule and Secondary Members Happy Monday, compliance friends! Today we’re going to talk about the National Credit Union Administration’s (NCUA) proposed rule regarding chartering and field of membership (FOM) regulations. Specifically, the portion dealing with the eligibility of immediate family members of decedents. Current Rule You can either be a primary or a secondary member of a credit union.
What should be included in your monthly board meeting report?
Has your credit union ever wondered what must be included in a monthly board meeting report? If so, read on for some helpful tips! While there is no comprehensive list stating what must be included, most credit unions have fairly comprehensive packets each month based on what the board needs to review that particular month (such as if certain policies are up for review, etc.) A good starting place is the Federal Credit Union Act (FCU Act).
What Should Be Included in Your Monthly Board Meeting Report?
Has your credit union ever wondered what must be included in a monthly board meeting report? If so, read on for some helpful tips! While there is no comprehensive list stating what must be included, most credit unions have fairly comprehensive packets each month based on what the board needs to review that particular month (such as if certain policies are up for review, etc.) A good starting place is the Federal Credit Union Act (FCU Act).
Are rates required to be posted on credit union websites?
Are credit unions required to post rates to their websites? While there are no requirements to do so, credit unions should note that there are rules in section 707.8 regarding advertising that would likely apply if the credit union does post rates online. The commentary advises on permissible rates and states that: “1. Tiered-rate accounts.
Are Rates Required to Be Posted on Credit Union Websites?
Happy Wednesday, compliance friends! Today is a special day (at least in my household) because it’s my cat’s 15th birthday! Here is a picture of Quincy in his “shrimp” pose to add some cuteness to your day: Now on to the topic of this blog: Are credit unions required to post rates to their websites? While there are no requirements to do so, credit unions should note that there are rules in section 707.8 regarding advertising that would likely apply if the credit union does post rates online.
Converting from a state to a federal charter
Occasionally NAFCU will receive questions from credit unions regarding converting from a state to a federal charter. If your state-chartered credit union ever makes this decision, I’ve included some helpful information below that may help you in your conversion.
Address Confidentiality Programs and Customer Identification; Programming Note
The PATRIOT Act and federal regulations require each credit union to implement a written Customer Identification Program (CIP) that includes certain minimum requirements, such as the collection of identifying information at account opening and risk-based identity verification procedures. But what happens when a customer is part of an address confidentiality program (ACP)?
UCC tricks and treats!
I hope everyone has a Halloween filled with more treats than tricks! Speaking of tricks, what happens when a credit union receives a check that has double the forgery? For example, the drawer’s signature AND the endorsement are both forged. Generally, check transactions are governed by Article 4 of the Uniform Commercial Code (UCC), which is adopted individually, as state law.
Mortgage servicing transfer notices
Hello everyone! My name is Tara Simpson, and I hail from the great state of Michigan. I am a new Regulatory Compliance Counsel at NAFCU, and I’m excited to bring to you my first ever blog post! Before we get started, I’d also like to introduce you to my cat, Quincy, who serves as my unofficial “office manager”. He enjoys jumping up on my desk during the day to ensure I stay alert! Now, today we’re going to be talking about mortgage servicing transfer notices.
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