Important Agency Updates, News, Resources, and Tools

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A virtual roundtable discussion entitled “Update From Prudential Regulators” was held on May 13 and is now archived for viewing. Panelists included Rodney Hood, chairman of the National Credit Union Administration (NCUA), and regulatory officials from the Federal Deposit Insurance Corporation (FDIC), Office of the Comptroller of the Currency (OCC), and the Federal Reserve.

Download CUNA’s Capital Planning Worksheet
The Credit Union National Association’s (CUNA) Research and Statistics Division has developed a capital planning worksheet to help credit unions estimate and evaluate a credit union’s likely financial stress and resilience during the COVID-19 crisis. The model looks at a credit union’s historical experiences through the lens of the Great Recession of 2007 – 2009. Evaluating this historical crisis-environment experience may help credit unions make reasonable assumptions about expectations during the COVID-19 crisis.

Using a series of graphics and tables, the model summarizes the mathematical relationships between asset growth rate and return on assets (ROA). To access and start using the spreadsheet, click here and then download it. To download, click on the down-arrow on the right side next to the blue sign-in button. Once downloaded, credit unions may need to click “Enable Content” on the toolbar to get started, then enter the credit union’s charter number. This will automatically insert the credit union’s 5300 data. The “Model Overview” tab provides specific information and use for each chart in the spreadsheet.

For additional questions on the spreadsheet and its use, email Rick Stanton.

NCUA’s May 22 Deadline: Apply for CDRLF Grants
Eligible low-income credit unions have until May 22 to apply for the NCUA’s Community Development Revolving Loan Fund grants. The NCUA is committing $1.375 million in grants to COVID-19-related efforts. The agency will not make grants in the traditional categories in 2020.

Credit unions may apply through the NCUA’s CyberGrants portal. The NCUA’s Office of Credit Union Resources and Expansion will work to review grant applications as quickly as possible. Credit unions should review the agency’s grant guidelines prior to submitting their applications.

The grants, with a maximum award of $10,000, will be awarded on a rolling basis throughout the open application period. Minority depository institutions and credit unions with less than $100 million in assets will receive priority. The NCUA will make awards on a first-come, first-serve basis until the earmarked funds are fully exhausted.

Questions? Contact the Office of Credit Union Resources and Expansion by email at CUREApps@ncua.gov.

NCUA: Corporate CUs Join CLF as Members
NCUA Chairman Rodney Hood announced that all 11 corporate credit unions have joined the agency’s Central Liquidity Facility (CLF) as agent members. All credit unions with assets of less than $250 million that are members of a corporate credit union are now eligible to apply for a loan from the CLF, extending coverage to more than 3,700 credit unions and increasing the CLF’s borrowing capacity by more than $13 billion. This agent network sunsets on Dec. 31, 2020.
 
NCUA had initially provided information on changes to the CLF because of the CARES Act (temporary authority for a corporate credit union to become an agent member of the CLF).
 
If your credit union is covered by these new CLF agent members, you can work directly with your corporate credit union to request a CLF loan.
 
NCUA Includes Military Personnel in Low Income Designation
The NCUA announced it is expanding its approach when considering military personnel in determining whether a credit union qualifies for the low-income designation. To qualify as a low-income credit union, a majority of the credit union’s membership must meet certain low-income thresholds, based on data from the Census Bureau and requirements outlined in the NCUA’s Rules and Regulations.
 
Under the new approach, military personnel will now be considered in a similar manner as students attending colleges, universities, vocational or technical schools when the NCUA evaluates a federally insured credit union’s low-income designation. You can read more here.
 
Allowances for Credit Losses; Credit Risk Review Systems
Four federal financial regulatory agencies, including the NCUA, have approved a policy statement on allowances for credit losses. They also finalized interagency guidance on credit risk review systems. You can view the announcement here.
 
NCUA Reminder on CFPB Interpretive Rule
NCUA issued an alert reminding credit unions that the CFPB issued an interpretive rule on May 4 to clarify when consumers can elect to modify or waive certain required waiting periods for some mortgage loans due to the COVID-19 pandemic. The interpretive rule, effective immediately, specifically addresses waivers of required waiting periods under the TILA-RESPA Integrated Disclosure (TRID) rule and the Regulation Z right of rescission rule. Read more here.

CFPB on Financial Responsibility During Pandemic
The Consumer Financial Protection Bureau (CFPB) released a statement and FAQ sheets outlining the responsibility of certain financial firms during the pandemic. The bureau outlines the billing error responsibilities of credit card issuers and other open-end non-home secured creditors during the COVID-19 pandemic. Additionally, the bureau encourages financial firms to continue to provide the kind of assistance to their communities that many have been providing, such as waiving fees, lowering minimum-balance requirements, and implementing changes in account terms that benefit consumers.

The first FAQs sheet remind providers of checking, savings, or prepaid accounts that they can offer consumers immediate relief by changing account terms without advance notice where the change in terms is clearly favorable to the consumer. The bureau’s second FAQs sheet focuses on existing regulatory flexibilities for open-end credit (that is not home-secured) that may be useful for assisting customers. For example, there is no advance notice requirement should a creditor choose to extend a credit card account’s grace period.

CFPB Issues Final Remittance Rule
The CFPB has issued a final rule covering remittances transfers. The rule increases the threshold that determines whether an entity makes remittance transfers in the normal course of its business and is subject to the rule. Entities making 500 or fewer transfers annually in the current and prior calendar years would not be subject to the rule, which will reduce the burden on nearly 250 credit unions and more than 400 banks that send a relatively small number of remittances.

The rule also allows certain credit unions and banks to continue providing estimates of the exchange rate and certain fees under certain conditions. This could preserve consumers’ ability to send remittances from their bank accounts to certain countries or recipient institutions. You can view the final rule.

FHFA Extends Foreclosure and Eviction Moratorium
To help borrowers and renters who are at risk of losing their home due to the coronavirus national emergency, the Federal Housing Finance Agency (FHFA) announced that Fannie Mae and Freddie Mac are extending their moratorium on foreclosures and evictions until at least June 30, 2020 (instead of May 17). The foreclosure moratorium applies to GSE-backed, single-family mortgages only. Read more here.

FHFA: New Payment Deferral Option in COVID-19 Forbearance Plans
The FHFA also announced that Fannie Mae and Freddie Mac are making available a new payment deferral option. The payment deferral option allows borrowers who are able to return to making their normal monthly mortgage payment the ability to repay missed payments at the time the home is sold, refinanced, or at maturity. Payment deferral is one of the repayment options.

Payment deferral takes the missed mortgage payments and puts them into a payment due at the sale, or refinancing of the home, or the end of the loan. The borrower's monthly mortgage payment will not change. Mortgages that exercise the payment deferral option will remain in Enterprise Mortgage-Backed Securities, subject to the terms of the trust agreements. Servicers will begin offering the payment deferral repayment option starting July 1, 2020. In addition to the new payment deferral option, borrowers with COVID-19 related hardships can still utilize other options that include reinstatement, repayment plan, or loan modifications based on their individual situations.

New Interagency Website on Housing Assistance
To ensure homeowners and renters have up-to-date housing assistance information, the CFPB, FHFA, and Department of Housing and Urban Development (HUD) have launched a new mortgage and housing assistance website. This website consolidates consumer information on the CARES Act mortgage relief, protections for renters, resources for additional help, and how to avoid COVID-19 related scams. It also provides tools to determine if one’s mortgage is federally backed, and for renters to find out if their unit is financed by FHA, Fannie Mae, or Freddie Mac.

Additionally, the CFPB has launched individual COVID-19 resource webpages for consumers on student loans, mortgage reliefeconomic stimulus payments, small business assistance, and financial decision resources. Please feel free to use as needed in communicating with your members.

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