A resource for credit unions in CA & NV, providing credit union financial and economic trend analysis, brought to you by your Leagues in partnership with CUNA & Affiliates.
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TIPs Posted Last Week
New TIPs Bulletins (Technical Information and Procedures) have been posted!
TIPs Bulletin 13-45 discusses Assembly Bill 212. This law has lowered the aggregate reporting threshold when reporting escheated property to the State Controller's Office (SCO) from $50 to $25, beginning on July 1, 2014. AB 212 also requires that the Unclaimed Property report that is sent to the Controller must include the name and last known address of each person appearing to be the owner of any property, except traveler’s checks and money orders, worth at least $25 (lowered from $50).
TIPs Bulletin 13-46 outlines the Leagues' understanding from speaking with the California Department of Business Oversight (DBO) regarding its expectations in response to a recent DBO notice. The Oct. 7 notice informs state-licensed banks and credit unions in California of their responsibility to identify and report payment transactions sent through the ACH network that may have been transmitted by unlicensed online payday lenders.
CFPB Publishes Remittance Procedures
The Consumer Financial Protection Bureau (CFPB) has published the procedures it will use in examining institutions that make remittance transfers for consumers.
Additionally, the bureau is releasing eRegulations, an online tool designed to make regulations easier to understand.
The rule, which went into effect Oct. 28, has been subsequently revised to address concerns related to some specific implementation challenges. Click here to access the remittance transfer examination procedures.
Click here for resources on the CFPB’s remittance transfer rule.
Multi-Agency Guidance on QM Fair Lending Risks
Five federal regulatory agencies have issued a statement to address industry questions about fair lending risks associated with offering only Qualified Mortgages.
Creditors have asked for clarity regarding whether the disparate impact doctrine of the Equal Credit Opportunity Act (ECOA) and its implementing regulation, Regulation B, allows them to originate only Qualified Mortgages. For the reasons described in the statement, the five agencies do not anticipate that a creditor’s decision to offer only Qualified Mortgages would, absent other factors, elevate a supervised institution’s fair lending risk.
The statement has been issued by the Board of Governors of the Federal Reserve System, Consumer Financial Protection Bureau (CFPB), Federal Deposit Insurance Corp. (FDIC), National Credit Union Administration (NCUA), and the Office of the Comptroller of the Currency (OCC).
UNCLAIMED PROPERTY HANDBOOK
updated 04/26/16 07:15 AM
Plus, Title XIV Mortgage Updates
California State Controller's Office has issued an updated Unclaimed Property Holder Handbook with changes to reflect:
CREDIT CARD SUBMISSION GUIDANCE
updated 04/18/16 12:02 PM
Plus, Compliance Advice Webinar
The Consumer Financial Protection Bureau (CFPB) has issued guidance for credit card issuers with simplified instructions for making the required submissions under Regulation Z. Last year, the CFPB temporarily suspended this rule until April 30, 2016. Issuers have to submit credit card agreements to the Bureau by May 2, 2016, and quarterly thereafter.