Compliance Blog

Jan 22, 2009
Categories: Consumer Lending

Hold Your Horses; Electronic Stop Payments?; Allen Wrenches

President Obama has asked federal regulators to hold off on finalizing new or proposed regulations.  His request also includes possible extensions on existing compliance deadlines.  Read all about it here, in a very good NAFCU Today article.   The article provides a good overview, as well as a link to the White House Memorandum. 

NCUA has already pulled one final rule back due to the memo.  NCUA officials report that it is possible that other rules, including UDAP, could be affected.  Stay tuned.

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Electronic stop payment orders?  You bet, says NCUA, as far as it is concerned.  In Legal Opinion Letter 08-1122 (January 5, 2009), NCUA indicates that NCUA regs do not require a signed, paper form.  But they do ask that credit unions look at state law requirements on the subject.  The letter is a good refresher on NCUA's recordkeeping requirements.

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The two cribs are built.  So is a chest of drawers.  I have two words to describe my recent long weekend: allen wrench.  A bunch of folks have been asking, so I just wanted to pass along that Mandy is doing well and that the dynamic duo should be along in mid-March.