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InfoSight Newsletter

Leagues that utilize InfoSight are able to offer a weekly e-newsletter to their credit unions. It can be customized for each league and is emailed every Wednesday. Take a look below at an example of the InfoSight Compliance e-Newsletter.

Risk Assessment
The Risk Assessment is a necessary first step to developing adequate policies and procedures. There are two steps to developing a risk assessment:

  1. The creation of a risk profile by reviewing the risks inherent in the credit union’s products, services, members and geographic location
  2. Conducting a detailed analysis of data identified during the development of the risk profile

The analysis should assist your credit union in identifying vulnerabilities and developing processes to manage those vulnerabilities.

A credit union's risk assessment should be well documented and should be reassessed at least every 12 to 18 months. Regulators suggest that a credit union's risk assessment be considered a living document.

Examiners may complete a risk assessment if a credit union has not completed one prior to an exam or if the risk assessment provided is insufficient. Risk assessments created by examiners are for examination purposes and will not be as detailed or comprehensive as the risk assessment that is expected from an institution.

For answers to frequently asked questions and additional information that can help your credit union stay in compliance, visit the Risk Assessment topic on the Bank Secrecy Act channel of InfoSight.

Upcoming Changes to the NACHA Operating Rules
NACHA provides a comprehensive list of recent and upcoming changes to the NACHA Operating Rules. Brief descriptions of the change and links to additional information including webinars can be viewed by clicking on the title of the rule change.

Effective SEPTEMBER 20, 2013

Source: NACHA


It's Almost September: Is Your CU Prepared?
As News Now has been reminding over the last month, September is National Preparedness Month. The Federal Emergency Management Agency (FEMA) is inviting all interested parties to join a collaborative "National Preparedness Community" to fulfill a "shared responsibility to prepare."

FEMA is also offering a downloadable 2013 National Preparedness Month Toolkit.

Those who join FEMA's virtual preparedness community (see resource link) also:

  • Get access to preparedness resources;
  • Can promote their national preparedness event on the calendar;
  • Can connect and build relationships with emergency management personnel; and
  • Can share and compare preparedness plans.

Credit unions should also be aware of three webinars to help them prepare that are being offered in September by Agility Recovery, the disaster preparedness business continuity service provider for CUNA Strategic Services (News Now Aug. 12). Agility Recovery is partnering with the U.S. Small Business Administration to offer the preparedness sessions.
 
Each of the free webinars all begin at 2 p.m (ET) and topics include:

  • Protecting Your Organization By Preparing Your Employees, Sept. 11;
  • The NEW 10 Steps to Preparedness: Lessons From the Past, Sept. 18; and
  • Crisis Communications For Any Organization, Sept. 25.

Agility Recovery also has prepared a free "Crisis Communications Planning Checklist for Credit Unions," available to download from its website. Use the third resource link to download a two-page checklist, which provides recommendations for developing a communications plan, as well as what to do during the crisis and after the crisis.

Agility has said the checklist can help credit unions assess their current strategy "and put into place some simple steps that will enhance your capability to communicate before, during and after the next disaster."

Other Resources:

Source: CUNA News Now


Federal Reserve Holiday Currency Ordering
The Federal Reserve has posted information regarding special request processing for 2013 holiday currency.  The special ordering periods will be October 18–24 and December 6–12.  Your credit union may place orders to meet its holiday currency needs using the FedLine Web® access solution, which provides easy to use features to request either fit currency or new currency. If the credit union would like to order both new and fit currency, you will need to place two separate orders — one for fit and one for new. All orders will be filled with the requested currency type unless the supply has been temporarily exhausted.

Source: Federal Reserve

Joint Agencies Re-propose QRM Rule

Numerous Federal banking agencies issued a joint revised proposed rule on credit risk retention, which defines the term qualified residential mortgage (QRM) for purposes of creating an exemption from the risk retention requirements under the Dodd-Frank Act.

CUNA strongly opposed the original rule in 2011 due to several aspects of the rule including: a down payment requirement of 20% as well as front-end and back-end debt-to-income ratios of 28 and 36%, respectively, among other items.

While few credit unions would likely be covered as securitizers of asset backed securities, this proposal is important because the secondary market will likely conform to qualified mortgage (QM) and QRM standards. CUNA is also concerned that examiners may insist credit unions confine their mortgage loans to QMs and QRMs.

Under the newly proposed rule, the definition of QRM would be revised to be the same as the CFPB’s definition of a QM, and contrary to the original proposal, there would be no loan-to-value, down payment, credit history, mortgage servicing or appraisal requirements for a mortgage loan to qualify as a QRM. However, home equity lines of credit, reverse mortgages, mortgages secured by timeshares and temporary or “bridge” loans of 12 months or less would not qualify for QRM status.

To provide CUNA a comment on the proposed rule click here.  Comments are due to the Joint Agencies on October 30, 2013.

Source: CUNA


Regulatory Advocacy Report
The CUNA Regulatory Advocacy Report contains information from Bill Cheney about regulatory issues that affect credit unions. You can view the current report and past reports from the archive

Newsletter Sign-up
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InfoSight
Compliance eNEWSLETTER

September 6, 2013
Vol. 7, Issue 36

Created in partnership with the

Credit Union National Association

Compliance Outlook: 2013 Second & Third Quarter

This edition of the CU Compliance Connection presented by InfoSight provides information on the compliance issues that your credit union has worked on in the second quarter of 2013, and the upcoming issues that we'll face in the third quarter. Click Here

September 2013
  • September 20th
    NACHA Rule Changes Effective Date
  • September 25th
    Loan Participations Rule Effective Date

October 2013

  • October 14th
    Columbus Day - Federal Holiday
  • October 22nd
    5300 Call Report Due to NCUA 
  • October 28th
    CFPB - Regulation E - International Remittances Final Rule - Effective Date 
  • October 31st
    CFPB - Credit Card Quarterly Agreement Submission Due (10,000 or more open credit card accounts) 

November 2013

December 2013

  • December 25th: Christmas Day - Federal Holiday
  • December 31st: ACH Compliance Review Deadline
  • December 31st: CFPB - Credit Card Quarterly Agreement Submission Due (10,000 or more open credit card accounts)

National

April 10 – October 10
CUNA Regulatory Compliance Introduction eSchool

September 8 - 11
CUNA Collections & Bankruptcy School
Tempe, AZ

September 14 - 15
CUNA Marketing Compliance School
Tempe, AZ

September 8 - 11
CUNA Regulatory Compliance School
Tempe, AZ

September 17
NCUA “Member Business Loans: Strategy and Policy Webinar”

September 18
CUNA The Basics of the Bank Secrecy Act webinar

September 24
CUNA ABCs of Policies webinar

September 25
NCUA “Member Business Loans: Underwriting”

October 2
CUNA Bank Secrecy Act eSchool

October 3
CUNA Safe Deposit Box Compliance eSchool

October 8
CUNA Update on Mortgage Lending Regulations webinar

October 15
NCUA Examination Preparation Strategies webinar

October 31
State Safe Deposit Compliance webinar

November 3 - 6
CUNA Bank Secrecy Act Conference
Orlando, FL

November 5
CUNA Mortgage Lending Compliance eSchool - The New Regulatory Environment