Identification Documents are vital in today’s world. After all, they’re how you prove that you’re really you. Recently I’ve been asked for ID when visiting the doctor and picking my son up from summer camp. And, of course, credit union staff will often ask a member to present ID when conducting financial transactions. Given the …
Have you had a member call your credit union and ask if they can change their payment due date on their loan or credit card? If so, this blog is for you. We are going to go over the regulatory requirements for changing a member’s payment due date for both open-end and closed-end credit. Open-end …
Can a Credit Union Change a Members Payment Due Date? Read More »
In May 2023, the CFPB released a special edition of its Supervisory Highlights that reported on the unlawful junk fees including those in the mortgage servicing marketplace as well as other areas such as bank accounts, student loans, and auto loans. The junk fees the CFPB discovered in the mortgage servicing arena included charging excessive …
Can’t stop the feeling of wanting to branch out, but are afraid you may have to have an Act of Bergen’s to do so? Well, what if I told you that spreading your wings may not be as difficult as one may think? I’m not trolling you. Doesn’t appear that Branch liked that quip. Nonetheless, …
The Consumer Financial Protection Bureau (CFPB) finalized in part its proposed rule on consumer financial data rights under Section 1033 of the Consumer Financial Protection Act (aka Title X of the Dodd-Frank Act of 2010). This final rule establishes minimum attributes a standard-setting organization (SSO) must possess to receive CFPB recognition and to issue consensus …
Recently I’ve received a couple questions regarding whether or not federal credit unions can use the terms “certificate of deposit” or “CD” when it comes to describing share certificates. So, what does NCUA require when it comes to the correct terminology? In order to set the stage, I first want to note that section 707.2(a) …
On June 4, 2024, the Consumer Financial Protection Bureau (CFPB) released Consumer Financial Protection Circular 2024-03 (Circular). The Circular discusses whether having unlawful and/or unenforceable terms and conditions in a contract for consumer financial products and services are a violation of the Consumer Financial Protection Act’s (CFPA) prohibition on deceptive acts or practices. The short …
Are Unlawful Terms in Your Contract a Deceptive Act or Practice? Read More »
Last week, on May 30, U.S District Judge Brinkema of the U.S. District Court for the Eastern District of Virginia, granted in part and denied in part Navy Federal Credit Union’s (Navy FCU) motion to dismiss the consolidated complaint filed on December 17, 2023. The complaint, filed by nine plaintiffs, alleged that Navy FCU discriminates …
Credit unions that offer online wire transfers may want to pay attention to a lawsuit that is currently playing out in federal court in New York. Back in January, the New York Attorney General’s Office (NYAG) filed a federal lawsuit against Citibank. The lawsuit alleges violations of law relating to Citibank’s offering of online and …
Are Your Wire Transfers Also EFTs? Some Regulators Say Yes Read More »
On May 16, 2024, the U.S. Supreme Court ruled that the funding structure of the CFPB does not violate the Constitution’s Appropriations Clause which states that “‘[n]o Money shall be drawn from the Treasury, but in Consequence of Appropriations made by Law.” In other words, the fact that the CFPB is funded independently with money …
U.S. Supreme Court Rules the CFPB’s Structure is Constitutional Read More »
