The NCUA has made no bones about how important consumer financial protection regs will be to its examiners this year. In fact, the agency is requiring its exam team to review six specific consumer financial protection rules at all examinations when applicable to the credit union. Those six rules – and a few predictions from our team – are below.
Regulation E: Whereas last year’s Reg E exams focused on overdraft, this year the focus turns to EFT policies and procedures, as well as the credit union’s compliance with error resolution and initial account disclosure rules. Like most disclosures, you must look at the timing and content within the disclosures. This is something you could grab a quick sample of and audit prior to any examination.
FCRA: Examiners will want credit unions to demonstrate accuracy in their reporting to the credit bureaus. Here again, they are concerned with timing, especially as it relates to the date of first delinquency. Therefore, credit unions should double check that this is covered in policies, procedures and controls. Those documents should also be as detailed as possible when it comes to how the credit union handles member disputes related to credit reports.
continue reading »