Compliance Blog

Jan 24, 2012

Letters to Credit Unions; Interpretive Rulings & Policy Statements; Cordray Testimony

Written by Steve Van Beek

If you've tried navigating NCUA's website recently, you've probably noticed a few changes in terms of where information is located as well as the overall format.

I wanted to highlight a couple of items that might be useful.  

NCUA Letters to Credit Unions

The good part is NCUA has indicated which Letters are Active and which are Inactive in a status column next to each Letter to Credit Unions.  The 2012 Letters are here and the 2011 Letters are here.

The bad part?  I had to go back to 2002 before I found a Letter to Credit Unions that was Inactive.

NCUA has a policy of reviewing a third of its regulations each year.  I'm starting to think NCUA should include Letters to Credit Unions in that review as the mountain of guidance documents continues to grow each year.

Note:  Letters to Federal Credit Unions can be found here (there are currently no letters for 2012).

Interpretive Rulings & Policy Statements

NCUA's website also breaks down their Interpretive Rulings & Policy Statements (IRPS) by those "Currently in Effect" and those that are "Withdrawn."

This chart can be very helpful if you've found an IRPS that addresses your compliance question but you have an inkling the guidance might be outdated.  This is especially true as the IRPS itself does not indicate that it is withdrawn.  

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Director of the CFPB, Richard Cordray, will be testifying before a House of Representatives Subcommittee today.  You can find Cordray's planned testimony here. Â