Someone told me that tomorrow is Valentine’s Day. If you’re looking for love advice, you’ve come to the right place. Word on the street is the quickest way to make someone fall for you is a stare down from Chuck Norris… and probably roses. What would not be a good idea is to delegate the …
Board of Director: Delegable vs. Non-delegable Duties Read More »
This past December, the Federal Communications Commission (FCC) adopted rules intended to close the so-called “lead generator loophole” in the Telephone Consumer Protection Act (TCPA). According to the FCC, “lead-generated communications are a large percentage of unwanted calls and texts” received by consumers. To close this “loophole,” the FCC amended the definition of “prior express …
TCPA One-to-One Consent Rule, Effective January 2025 Read More »
Happy Tuesday, compliance friends! Over the past few months, I have received quite a few questions on what the requirements are for retaining periodic statements, so I thought it may be helpful to write a refresher blog surrounding these requirements. To start, NCUA provides general record retention guidelines that outline various record retention recommendations. This …
If your credit union issues credit cards or allows members to utilize peer-to-peer (P2P) payments, then you most likely interact with merchant category codes (MCCs). These four-digit codes denote the type of business involved in a transaction and are important to certain aspects of the financial services industry. For example, if a credit union offers …
In the Crosshairs: Firearms Merchant Category Code Read More »
On January 24 the Consumer Financial Protection Bureau (CPFB or bureau) proposed a rule with request for comment to prohibit covered financial institutions from charging nonsufficient funds (NSF) fees, when consumers initiate payment transactions that are declined “instantaneously or near-instantaneously.” The proposal would prohibit financial institutions from charging fees for instantaneously declined transactions, regardless of …
CFPB Proposes Rule to Prohibit NSF Fees for Instantaneous Transactions Read More »
On Monday January 23 NCUA issued its 2024 Supervisory Priorities outlining five primary areas of supervisory focus to assist credit unions in preparing for their exam. Exam activities focus on the areas that pose the highest risk to credit unions, credit union members, and the National Credit Union Share Insurance Fund (NCUSIF). For 2024, NCUA …
On January 17, 2024 the CFPB dropped the highly anticipated proposed rule on overdraft fees. This rule, if adopted, would amend Regulation Z and Regulation E to update regulatory exceptions for overdraft credit provided by financial institutions with assets over $10 Billion, which covers approximately the 175 largest depository institutions in the country. The compliance …
CFPB Proposes Rule to Limit Fee Income on Overdraft Loans Read More »
Happy January 18th everyone. It’s national Michigan day! Fun fact about America’s Credit Unions’ compliance team, one third of our team members live in Michigan. Did you know, people who live in Michigan are called Michiganders. Did you also know that on January 12, 2024, FinCEN released an updated Paycheck Protection Plan (PPP) FAQ? Specifically, …
FinCEN Updates PPP FAQ Clarifying Permission to Acknowledge Filing of a SAR to SBA Read More »
On December 28, 2023, the National Credit Union Administration (NCUA), together with the Comptroller of the Currency, Board of Governors of the Federal Reserve System, and the Federal Deposit Insurance Corporation, (collectively, the Agencies) published a final rule to amend the Uniform Rules of Practice and Procedure (Uniform Rules). This action was listed on NCUA’s …
NCUA and Other Agencies Update the Uniform Rules of Practice and Procedure Read More »
Hello, Compliance friends! As we promised in our first blog post, this Compliance Blog will provide updates on important developments relating to credit union compliance. I’m a confessed Bank Secrecy Act (BSA) nerd, so naturally I’ve decided to focus my first post on a major recent development relating to BSA compliance: the recent final rule …
