Compliance Blog

Posted by Anthony Demangone

The NCUA Board Meeting agenda is set for this Thursday.  Here's what is on the open agenda:

1. Withdrawal of Final Rule – Part 706 of NCUA’s Rules and Regulations, Unfair or Deceptive Acts or Practices.

2. Insurance Fund Report.

So goes UDAP.  NCUA is following the Fed in withdrawing the UDAP rule.  I would think that their rationale would be similar to the Fed's, which you can read here. Simply put, many of the protections found within the recent UDAP rule have been overtaken by the CARD Act.  Now that those protections are housed within Regulation Z, the need for UDAP seems, well, unfair and deceptive.  It is amazing to remember how frazzled we were when that UDAP rule was released in December of 2009.  Little did we know...

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NAFCU Members, the Reg Z overview document has been updated with the following sections:

1. Periodic statements sent 21 days before the due date; and
2. Increasing APRs due to a consumers default or delinquency, including the 60-day delinquency requirements.