NCUA exams to focus on loan accommodations and fair lending

Good morning, compliance friends! In the usual spirit of beginning a new year, we are getting some questions about upcoming compliance concerns.

In November, NCUA hosted a webinar (available on-demand) giving an update on consumer compliance expectations. NCUA explained that upcoming credit union examinations will focus on, among other things, loan accommodations triggered by the COVID-19 pandemic and common fair lending issues.

COVID-19 Accommodations

During the webinar, NCUA noted examiners have already begun to review loan accommodations and limits on credit reporting due to the pandemic. First, NCUA is reviewing credit union policies and internal controls to ensure credit unions have written plans in place to determine how accommodations are offered and how to report to credit bureaus. Additionally, NCUA examiners will be comparing CARES Act-related loans and non-CARES Act-related loans, as well as treating mortgage loans and consumer loans differently. For example, credit unions may be expected to monitor and work more closely with members while servicing CARES Act-related mortgage loans because these loans have been modified for members experiencing hardship.


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