Compliance Blog

Sep 18, 2015

Post-Caucus Regulatory Round-Up: NCUA Board Takes Action on Regulatory Flexibility Act and Aggregate Lending Limits; CFPB Releases Updated TRID Examination Procedures; FRB Announces 2015 Fair Lending Webinar

Written by Elizabeth M. Young LaBerge, Regulatory Compliance Counsel

Caucus is over and what a week it was! Meeting our members face-to-face and helping you make direct connections with your representatives here in Washington, D.C. has been fantastically rewarding. Thanks to all who attended! While credit unions were on the Hill, the regulators have been busy. Here are some highlights from the regulators this week.

NCUA Board Takes Action on Regulatory Flexibility Act and Aggregate Lending Limits

Today at NCUA's Board meeting, the board voted on final rules regarding the Regulatory Flexibility Act and the aggregate lending limit for corporate credit unions. The Board increased the asset threshold for small entity designation from $50 million to $100 million, and committed to reevaluating the threshold every three years. That will give some credit unions special consideration for regulatory relief. The Board also voted to exclude Central Liquidity Facility-related bridge loans from the aggregate unsecured lending cap on loans to one borrower by corporate credit unions. 

Also, at the board meeting, NCUA Chairman Debbie Matz recommended a policy change that would authorize the Office of Consumer Protection to approve community charter expansion requests that are currently reserved for board consideration. Earlier this year, NCUA began an internal review of its Field of Membership regulations in order to streamline procedural and regulatory hurdles that unnecessarily burden credit union growth.


CFPB Releases Updated TRID Examination Procedures

On Tuesday, the CFPB updated its Supervision and Examination Manual sections on Mortgage Origination Exam Procedures and TRID Examination Procedures for examinations after the October 2015 effective date. The updated examination procedures can be accessed here. While most credit unions will not be examined for consumer compliance by the CFPB, any guidance is helpful in trying to find one's way out of the dreaded TRID labyrinth.


FRB Announces 2015 Fair Lending Webinar

Also, on Tuesday, the Federal Reserve Bank of San Francisco has announced an inter-agency Outlook Live webinar on Fair Lending Hot Topics. The webinar will be 90 minutes long and cover CFPB mortgage updates, use of data in evaluating fair lending risk, compliance management, pricing, maternity leave discrimination, post-origination risks, auto lending settlements and others. Participating agencies include the DOJ, CFPB, FDIC, OCC, FRB, HUD and NCUA. The webinar takes place on Thursday, October 15, 2015 and requires registration which can be done here.