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Compliance Outlook

Compliance Outlook. 2013 Second Quarter -. Third Quarter. Program Overview. Second Quarter 2013 BSA – Forms & Filing CFPB – Escrow Requirements CFPB – Mandatory Arbitration Agreements CFPB – Credit Insurance NCUA – Investment Evaluation Joint Agencies - Garnishment. Program Overview.

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Compliance Outlook

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  1. Compliance Outlook 2013 Second Quarter - Third Quarter

  2. Program Overview • Second Quarter 2013 • BSA – Forms & Filing • CFPB – Escrow Requirements • CFPB – Mandatory Arbitration Agreements • CFPB – Credit Insurance • NCUA – Investment Evaluation • Joint Agencies - Garnishment

  3. Program Overview Third Quarter 2013 • FTC – COPPA • NCUA – Loan Participations • CFPB – 2014 Actions

  4. FinCEN – BSA E - Filing 4/1/2013

  5. CFPB – Escrow Accounts Escrow accounts must be established on Higher-priced mortgage loans and maintained for at least 5 years. • Exemption: • Serve rural & underserved areas • Assets < $2 billion • Originate < 500 first lien mortgages • AND • Not escrow currently or future 6/1/2013

  6. CFPB – Arbitration Agreements Binding arbitration requirements are prohibited. It also prohibits the application or interpretation of provisions of such loans or related agreements so as to bar a consumer from bringing a claim in court in connection with any alleged violation of Federal law. 6/1/2013

  7. CFPB – Credit Insurance Prohibits the financing of any premiums or fees for credit insurance (such as credit life insurance) in connection with a consumer credit transaction secured by a dwelling, but allows credit insurance to be paid for on a monthly basis. 6/1/2013

  8. NCUA – Investment Evaluation NCUA issued a final rule to implement statutory requirements in Dodd- Frank Act pertaining to the use of credit ratings to assess creditworthiness. The final rule removes references to credit ratings in NCUA regulations or replaces them with other appropriate standards of creditworthiness as required by the Dodd-Frank Act. 6/11/2013

  9. Joint Agencies - Garnishment Garnishment of Federal Benefit Payments: • Definition of a benefit payment amended; • Garnishment order includes: a levy, orders issued by States and municipalities, as well as orders to freeze assets; and • Applies to the balance in the account when the review is conducted. 6/28/2013

  10. 2013 Third Quarter Compliance Issues

  11. FTC - COPPA 7/1/2013 • COPPA Requires: • Online privacy policy; • Notice to parents; • Parental consenting to information collection and use; • Parental access to their child’s personal information; • Parents can prevent further use or collection of information; • Maintain the confidentiality, security, and integrity of information; and • Retain personal information collected online from a child for only as long as is needed for the purpose it was collected.

  12. NCUA – Loan Participations • Loan Participation Requirements Amended: • Purchasing credit unions subject to a concentration limit of $5 million or 100% of net worth, whichever is greater; • Originating federal credit union risk retention requirement is 10%; risk retention requirement for other originating organizations is 5%, consistent with the requirements under the Dodd-Frank; • Federally insured credit unions may establish different underwriting standards for loan participations. 7/25/2013

  13. CFPB

  14. Thank you for joining us for this overview of the Credit Union Compliance Connection. Stay Tuned……..

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