America’s Credit Unions’ Compliance Team continues to update the Compliance Blog every Tuesday and Thursday. The latest entries cover recent questions regarding whistleblower programs, open and closed-end advertising requirements, and the Children’s Online Privacy Protection Act (COPPA).
Recent blog posts include:
- “When are Credit Unions NOT Community Financial Institutions?” examines the definition of “community financial institution” (CFI) under the Federal Home Loan Bank Act. It currently excludes credit unions, as CFIs are defined in the act as members whose deposits are insured under the Federal Deposit Insurance Act (FDIC Act) and have assets under the calculated asset cap;
- “Whistleblowers & Confidentiality Agreements” covers government steps to encourage whistleblower activity, including the Department of Justice’s plans for a new whistleblower pilot program, the Financial Crimes Enforcement Network’s existing program relating to Bank Secrecy Act violations, and the CFPB’s new circular on whistleblower protections;
- “The Basics: Open and Closed End Credit Advertising Requirements” provides a refresher on regulatory requirements for both open-end and closed-end credit advertisements, including under Regulation Z; and
- “COPPA, and Not ‘The Copa’” covers the circumstances under which COPPA might apply to credit unions. COPPA imposes certain requirements on operators of websites or online services directed to children under 13. The blog also provides NCUA’s examination perspective on COPPA.
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