A sign of the times
Fine-tooth comb compliance strategies are becoming more common across the credit union movement – and for good reason. Today’s regulatory environment accepts nothing less than great attention to detail from staff across all departments. Credit union marketers and branch managers, for instance, are challenged to ensure even their signage is up to regulatory snuff.
Cooperatives of all sizes have countless signage collateral posted in their physical locations. Everything from marketing pieces to internal information requires notices. Among those, one of the most important is the Fair Housing Notice.
It’s not uncommon for a credit union to post this notice with incomplete or incorrect language.
The bad news – This could be perceived as a red flag to potential discriminatory housing practices. Worse, it could be noted in an exam.
The good news – This is a simple fix. A quick review of the regulation itself will solve that problem, as a model notice is included.
The model notice for federally chartered credit unions is included in NCUA Rules and Regulations, Part 701.31. Federally chartered credit unions can use the model along with the either the Equal Housing Lender or Equal Housing Opportunity logos.
State chartered credit unions follow HUD’s regulations instead; the HUD poster requirement is located at 24 CFR Section 110. Other than the actual look of this poster, the most important item to note is state chartered credit unions are only required to use the Equal Housing Opportunity logo.
Another NCUA required posting is the official sign. Each insured credit union must continuously display the official sign at each station or window where insured account funds or deposits are normally received. This applies to all branches.
The official sign is depicted as:
It’s also important to note there are other required branch signs. One of these includes the HMDA notice of availability as described in Regulation C, Section 1002.5(e). The model language provided reads as follows:
Home Mortgage Disclosure Act Notice
The HMDA data about our residential mortgage lending are available for review. The data show geographic distribution of loans and applications; ethnicity, race, sex, and income of applicants and borrowers; and information about loan approvals and denials. Inquire at this office regarding the locations where HMDA data may be inspected.
Another notice you will want to ensure you have posted is the Regulation CC, Funds Availability Notice. The model notice can be found in Appendix C of the regulation. The model language provided reads as follows:
Funds Availability Policy
Our general policy is to allow you to withdraw funds deposited in your account on the (number) business day after the day we receive your deposit. Funds from electronic direct deposits will be available on the day we receive the deposit. In some cases, we may delay your ability to withdraw funds beyond the (number) business day. Then, the funds will generally be available by the fifth business day after the day of deposit.
Attention to detail in the branch is crucially important. Credit unions should not only establish policies that designate an owner for compliance with required signage; they should also include ongoing review of signs and postings.
