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NCUA Letter on Lending Draws Reassurance to Credit Unions From CUNA Mutual Group
Rick Uhlmann
608.665.8940
rick.uhlmann@cunamutual.com
Michelle Larson
608.665.8310
michelle.m.larson@cunamutual.com
MADISON, Wis. — The National Credit Union Administration’s (NCUA) letter issued July 20 on multi-featured open-end lending (MFOEL) and blended lending brought a reassuring response to credit unions today from CUNA Mutual Group, the industry’s lending compliance leader.
The NCUA’s letter to federal credit unions confirms regulations continue to allow MFOEL. However, it provides limitations on the amount of information a credit union may gather at the time of an advance request, which will limit the use of MFOEL for some credit unions.
“The lending regulatory environment is evolving rapidly and more change is expected,” said Bill Klewin, CUNA Mutual Group’s director of regulatory compliance. “CUNA Mutual has worked with credit unions on lending compliance issues for more than 30 years and provides lending products that ensures compliance” said Klewin. “We will help credit unions through this change and continue to be here for them as the many new regulations emerge.”
In the letter, the NCUA also discussed blended or multi-featured lending (MFL) plans. NCUA clarified that open-end and closed-end lending are two distinct regimens and each require their own application, timing requirements and disclosures for the member-borrower.
The letter discussed blended loan programs, which combine open-end and closed-end processes and disclosures. The letter makes clear such an approach is not the same as a MFOEL program and that such an approach must follow the distinct rules for open-end and closed-end lending, depending on the nature of the transaction.
Klewin said CUNA Mutual Group welcomes the NCUA’s efforts to clarify the compliance requirements surrounding multi-featured open-end lending and blended lending and that the company will continue to support credit unions to ensure an effective balance of safety and soundness, member convenience and compliance requirements. CUNA Mutual Group has the products to support credit unions’ requirements for compliant and efficient lending programs. “As credit union staff reviews their lending policies and procedures, we are the dedicated resource to ensure selection of the best approach for credit unions and their members,” said Klewin.
CUNA Mutual Group is asking credit unions with LOANLINER®-related questions to contact its team of compliance and operations specialists at 800.356.5012, or email at loanlinercompliance@cunamutual.com.
CUNA Mutual Group insurance, retirement and investment products provide financial security and protection to credit unions and their members worldwide. With more than 75 years of true market commitment, CUNA Mutual Group’s vision is unwavering: To be a trusted business partner who delivers service excellence through customer-focused products and market-driven insight. More information on the company is available on the company’s website at www.cunamutual.com
CUNA Mutual Group is the marketing name for CUNA Mutual Holding Company, a mutual insurance holding company, its subsidiaries and affiliates. Life, accident, health and annuity insurance products are issued by CMFG Life Insurance Company. Property and casualty insurance products are issued by CUMIS Insurance Society, Inc. Each insurer is solely responsible for the financial obligations under the policies and contracts it issues. Corporate headquarters are located in Madison, Wis.